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Home My WebLink About6801_OrangeCoMSWLF_PostclosureLanduse_App_FID1274688_20171018 October 18, 2017 Mr. Edward F. Mussler, III, PE, Permitting Branch Supervisor Solid Waste Section, NCDEQ, Division of Waste Management 1646 Mail Service Center Raleigh, NC 27699 RE: Operational Plan Revision Closure Certification and Continuing Operations; Orange County Regional Landfill Permit No. 6801-MSWLF-1993, Orange County Draper Aden Associates Project No. R00592-00 (via email) Dear Mr. Mussler: Pursuant to the request included in the September 29, 2015 letter (Document ID No. 25039), and on behalf of the Orange County Solid Waste Management Department, we are submitting a revised operational plan for the above referenced facility and permit. Even though the MSW landfill has ceased operation and has been closed, the attached operational plan has been revised to address the continuing operations of multiple activities included under this specific permit such as: • Household Hazardous Waste Collection*; • Tire Collection; • Yard waste Management; • Wood Grinding; • C&D Recycling; * A new and updated waste and recycling center is currently being constructed on the north side of Eubanks Road at the former location within the facility. A new household hazardous waste collection facility building is included. The facility is expected to open early 2018. A new separate permit for the new household hazardous waste facility will be sought prior to opening of the facility for operation. Please feel free to contact me at tclayton@daa.com or the numbers above or you can contact Gordon Dively, Orange County Interim Solid Waste Management Director at (919) 968-2788 should you need further revisions or wish to discuss. Sincerely, Draper Aden Associates C. Tyrus Clayton, Jr., PE Senior Project Manager attachment cc: file Gordon Dively, PE, Orange County Solid Waste Management Kevin Lindley, PE, Orange County Solid Waste Management John Patrone, NCDEQ-Solid Waste Section Shannon Aufman, NCDEQ- Solid Waste Section Orange County Landfill Operating Permit Modification - Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 ORANGE COUNTY LANDFILL OPERATING PERMIT MODIFICATION SECTION IV OPERATIONS PLAN Orange County Landfill Operating Permit Modification - Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Table of Contents – Page IV-i OPERATIONS PLAN TABLE OF CONTENTS A. INTRODUCTION ...................................................................................................................... 1 1. Purpose ............................................................................................................................ 1 2. Operator Responsibility ................................................................................................... 1 B. OPERATIONS METHODS AND PROCEDURES ................................................................ 2 1. Overview .......................................................................................................................... 2 2. Hours of Operation .......................................................................................................... 2 3. Site Access ....................................................................................................................... 2 4. Waste Acceptance and Special Waste Handling ............................................................. 2 5. Calculated Capacity ......................................................................................................... 3 6. Equipment ........................................................................................................................ 3 7. Access Roads ................................................................................................................... 3 8. Vehicle Control and Unloading ....................................................................................... 4 9. Waste Handling Operations ............................................................................................. 4 10. Cover Operations ............................................................................................................. 5 11. Surface Water Control ..................................................................................................... 5 12. Cleanup Activities ........................................................................................................... 5 13. Vector and Odor Control ................................................................................................. 5 14. Dust Control..................................................................................................................... 6 15. Erosion Control ................................................................................................................ 6 16. Tires ................................................................................................................................. 7 17. Record Keeping ............................................................................................................... 7 C. MONITORING AND INSPECTION PROCEDURES ........................................................... 8 1. Groundwater Monitoring Plan ......................................................................................... 8 2. Landfill Gas Perimeter and Interior Monitoring .............................................................. 8 3. Site Evaluations ............................................................................................................. 13 D. CONTINGENCY PLANNING ................................................................................................ 13 1. Wet Weather Operations ............................................................................................... 13 2. Fire Control .................................................................................................................... 13 3. Hazardous Wastes .......................................................................................................... 14 4. First Aid ......................................................................................................................... 14 5. Leachate Disposal .......................................................................................................... 15 E. STAFFING ................................................................................................................................ 15 1. Positions ......................................................................................................................... 15 2. Training.......................................................................................................................... 16 F. SAFETY ..................................................................................................................................... 16 1. General ........................................................................................................................... 16 2. Equipment ...................................................................................................................... 17 3. Personnel........................................................................................................................ 18 Orange County Landfill Operating Permit Modification - Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Table of Contents – Page IV-ii ATTACHMENTS Attachments IV-A through IV-F are not proposed to be modified and are not included in this Application for an Operating Permit Modification. They are listed here for reference only and can be found in the Construction Permit Application (NCDENR Document ID: 6801-MSWLF-1982; Description No: 6821). Attachment IV-A Paint Filter Test (Not Applicable) Attachment IV-B Waste Handling Guidelines (Not Applicable) Attachment IV-C Waste Screening Procedure (Not Applicable) Attachment IV-D Inspection Items Attachment IV-E Sedimentation and Erosion Control Plan Attachment IV-F Operations Manual for Orange County Permanent Household Hazardous Waste Collection Facility (Not Applicable) Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -1 A. INTRODUCTION 1. Purpose The purpose of an operations report is to provide the facility operator with a resource document that has guidance and information to enable the operator to better operate the site. No manual or textbook can be an effective substitute for a qualified and experienced operator. The lessons learned from time spent at the facility do not always easily reduce to words. However, a manual such as this can be a resource for an operator to rely upon for information and guidance. This current revision of the Orange County Landfill Operations Plan reflects the closure of the Municipal Solid Waste (MSW) landfill but addresses the continuation of other solid waste related activities at the facility. The manual is divided into several sections. The subjects covered are: • Operating Methods and Procedures • Monitoring and Inspection Procedures • Contingency Planning • Staffing • Safety A more detailed breakdown of subjects is in the table of contents. 2. Operator Responsibility The facility operator has responsibilities in several areas. The term operator as described here may actually encompass the duties of several people. This section is intended to convey the overall responsibilities of the facility operator function, not a specific job description. One operator responsibility is financial; fee collection, accounting, budgeting, cost effective purchases and use of resources. Another responsibility is personnel management; hiring, training, safety, promotion, scheduling. In addition, the facility operator has responsibilities for operations (equipment, maintenance, security, filling, environmental controls) and planning (new working areas, emergencies, inclement weather, equipment replacement, site improvements). Whether these responsibilities are handled by one person or shared by several people, skillful execution of these duties can make the facility successful. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -2 B. OPERATIONS METHODS AND PROCEDURES 1. Overview This section of the operations manual is intended to give the operator of the solid waste facility some techniques and procedures to help operations run smoothly and achieve the goal of environmentally sound waste disposal. The operator has an important role to play in the development of the facility. The day to day operation will determine the quality of the facility, perhaps more than the initial construction. The operator must understand the purpose of each of the ongoing waste management activities at the closed landfill. Otherwise, seemingly unimportant elements of the facility may be neglected even though they might be crucial to its success. The operator should be familiar with, and refer to, the EPA’s Subtitle D regulations, the rules and regulations of North Carolina’s Department of Environment and Natural Resources, Division of Waste Management (the Division) and the North Carolina Erosion and Sediment Control Planning and Design Manual. In addition, the operator must understand such things as financial controls, public relations, employee relations and planning for emergencies. By mastering the knowledge and skills necessary to become successful, the landfill operator is a professional in the waste disposal industry rather than “the guy who runs the dump”. 2. Hours of Operation The waste management facilities at the Orange County Landfill is open from 7:00 a.m. until 4:00 p.m., Monday through Friday, and from 7:30 8:00 a.m. until noon on Saturday (Effective July 2017). The MSW landfill is closed and no longer accepts waste for disposal. 3. Site Access Access to the facility is controlled by a locked gate at the entrance to the site along Eubanks Road. The area is surrounded by heavily wooded areas or natural barriers limiting access. A gate attendant is present during operating hours to screen incoming loads. The attendant screens out unauthorized vehicles and vehicles with unauthorized cargo. Those not permitted into the facility will be turned away at that point. In addition, the vehicles that have waste products accepted by the facility, such as yard waste, tires and white goods, are directed to special unloading areas. Signs are posted at or near the facility entrance that provides information on the hours that the facility is open for public use, the permit number, information regarding materials accepted, directions to separate disposal areas for wastes requiring l handling, information regarding the waste screening program, and other pertinent information. 4. Waste Acceptance and Special Waste Handling This facility may accept yard waste, tires, electronics, metals, clean wood, pallets, mattresses, and white goods for collection and recycling or disposal off-site. There are also designated C&D Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -3 recycling and wood grinding areas on-sites to be activated for processing disaster debris for disposal off-site. A Household Hazardous Waste collection facility also is present on-site under separate permit. Materials accepted at the facility will be directed to special handling areas. 6. Equipment The facility, including the separately permitted C&D landfill and solid waste and recycling operations located on the north side of Eubanks Road, currently uses the following equipment. C&D Landfill:  one dozer  one compactor Mulch Management:  one bucket loader MSW Landfill: (CLOSED) Metal and White Goods Handling:  hoe  two 90-cubic yard trailers  tractor Wood Grinding Operation:  horizontal grinder  track loader  hoe  conveyor  trommel screen  walking floor trailer Miscellaneous:  dozer  motor grader  water truck  off-road truck  repair truck  sweeper This equipment is adequate for operations. Equipment from one area can supplement equipment in other waste management areas and equipment is subject to change based upon operational need. In the event of an extended breakdown of equipment, the County has funds set aside for temporary rental of replacement equipment. This list of equipment may vary depending upon replacements and additional purchases. 7. Access Roads The County maintains a system of all-weather access roads at the facility to allow customers to access the various collection locations and to allow the County to process and remove collected materials and maintain the closed MSW landfill Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -4 8. Vehicle Control and Unloading Customers entering the facility will be controlled by the operations staff using the following procedures: a. Eliminate traffic that does not need to go to the facility. A household convenience center is provided on the north side of Eubanks Road for use by residents. b. Screen and weigh incoming traffic at the Attendants Station. Incoming vehicles will stop at the Attendant's Building. The Attendant can screen out unauthorized vehicles and vehicles with unauthorized cargo. Those not permitted into the facility will be turned away at that point. Vehicles admitted to the facility will be directed to the appropriate unloading areas based on material being delivered. c. An adequate number of directional signs are posted to control the flow of traffic. Signs are large enough and brightly marked to attract the drivers’ attention. Signs will be kept clean so they can be read. Commercially manufactured reflectorized signs are recommended because they are quite durable and will last many years. Spares should be maintained to replace signs that may be damaged. 9. Waste Handling Operations The facility maintains the following services: • a landfill gas collection system, • collection and processing of vegetative waste, • collection of metal for recycling, • mulching of separated yard waste and clean wood waste, and sale of mulch and compost, • tire collection for recycling, • shingles collection for recycling • white goods collection with removal of residual freon gas prior to recycling, • electronics collection for recycling • recycling processing for sorting, preparing and baling plastics bottles, metal cans and glass bottles for market, • hazardous household waste collection ( to be under separate permit – The County is currently constructing an updated and expanded waste and recycling collection facility on the north side of Eubanks road. It is expected to open for service in early 2018. A separate permit will be sought for the new HHW facility.), All materials are removed from the facility by the County or vendors. No materials are permanently disposed at the facility. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -5 11. Surface Water Control The closed MSW landfill at the facility uses a system of diversion berms, swales, and piped slope drains to perimeter drainage channels to avoid erosion of the final cover. The perimeter drainage channels discharge to a sediment basin before collected runoff is discharged off-site. These controls were designed for the 25-year, 24-hour design storm and are periodically inspected and repaired as necessary. Additional controls are constructed to divert stormwater away from the remaining material collection and processing facilities located on-site in order to provide customers with all-weather access. The diverted stormwater from these locations is also directed to sediment basins prior to off-site discharge. Stormwater discharged from the site is subject to NPDES permitting requirements. 12. Cleanup Activities During the day to day operation of the facility, debris will be spilled on the roads, litter will blow from thecollection areas, mud will accumulate in the ditches, and the dirt will be tracked on the roads. These are unavoidable circumstances and are common to allwaste management facilities. One of the characteristics of a well run facility is that litter, debris and mud are cleaned up on a regular basis. The most successful techniques are a combination of a continuing program and periodic major clean up campaigns. One of the "extra duties" that all employees should share is site clean up. Operators can pick up blowing litter during periods when they are not performing their primary task. The entrance will be cleaned up daily. Other employees can assist with that job particularly during periods of windy weather in the spring. Windblown material will be collected at the conclusion of each operating day. 13. Vector and Odor Control The closure of the MSW landfill and the operation of the landfill gas collection system should eliminate the primary potential source of vectors and odors at the facility. If abnormal quantities of vectors or odors are detected, then the landfill final cover and gas collection system will be inspected and any repairs or operational changes will be made to control nuisances. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -6 The remaining material collection and processing activities at the facility are generally not associated with the attraction of vectors or generation of odors. If local problems are detected, the sources of odors or vector attraction will be identified and removed or contained. If necessary, authorized methods of vector control/removal will be used. 14. Dust Control Excessive dust can be a nuisance and a hazard. Dust can irritate eyes and lungs. Water can be used but only to the extent that no saturation or ponding occurs. Maintaining areas for use in wet weather and removing mud deposited on roads will also minimize dust generated. 15. Erosion Control Erosion control at the facility will comply with the permit drawings and the approved sedimentation and erosion control plan. A copy of the sedimentation and erosion control plan is attached as Attachment IV-E of the Construction Permit Application (NCDENR Document ID: 6801-MSWLF- 1982; Description No: 6821). No major earth moving activities are anticipated for the facility since the MSW landfill has been closed. Erosion control will consist of maintaining the various components of the site drainage system, including sediment basins. Vegetation will be maintained on the closed landfill and other areas of the site not used for material collection and processing. Erosion control maintenance will consist of three activities. Each will be addressed separately but should be considered an integral part of the erosion control process. a. Maintenance of existing slopes and ditches involves inspecting and repairing areas where water has been directed and are subject to erosion. Repair may consist of refilling washouts or ditches, lining with stone or riprap, or cutting new ditches when the old ones are full. b. Temporary sediment barriers will be used at the base of slopes when any repair operation begins and continued until vegetative cover is established. Silt fences, and/or brush barriers can be used. Either type will have to be replaced periodically. Brush barriers typically maintain their effectiveness throughout the construction period. Silt fences should be constructed using a non-woven geotextile fabric that is resistant to ultraviolet light and is specifically manufactured to be used in siltation control fences. Brush barriers will be brush, stone, root mat, and other spoil material. The barrier will be mounded in a row with a minimum of five feet in width and three feet in height. Temporary sediment barriers will be inspected after each significant rainfall. c. The vegetative cover, sufficient to restrain erosion, should be maintained. Any repair area to be seeded should be tested for nutrients and pH, and fertilized as needed. These must be worked into the top one inch of the surface. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -7 Apply seed at the following rate: 100 lb/acre ............... Kentucky 31 Tall Fescue 30 lb/acre ................. Sericea Lespedeza 10 lb/acre ................. Kobe Lespedeza 25 lb/acre ................. Pensacola Bahiagrass Hydroseeding may be used in lieu of hand seeding or mechanical seeding. Seeded areas must be mulched to protect the seed until a stand of grass is established. The County reserves the right to revise the seeding mixture based on seasonal variations. 16. Tires Whole tires are collected at the facility from customers and are currently being removed from the site by a private contractor. 17. Record Keeping The facility maintains records of its activities. At a minimum, the following records will be maintained at the facility following closure of the MSW landfill [from list provided by NCDEQ, Waste Division]: Operating Record Includes e. Amounts by weight of solid waste received at the facility to include source of generation. f. Landfill Gas monitoring results and remediation plans required. g. Demonstration, certification, finding, monitoring, testing, or analytical data required by Rules .1630 through .1637. h. Monitoring, testing or analytical data as required by Rule .1627. i. Cost estimates and financial assurance documentation required by Rule .1628. j. Other Required Recordkeeping a. Contingency Plan. c. Scrap Tire Certification Forms (scrap tire collection, processing and disposal sites). d. Operation Plan. [.1626(10)(c)] e. Leachate Management Plan .1626(12) (sites with leachate collection system only). h. Records of monitoring information required by the Permit .1604(2)(K)(ii). Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -8 C. MONITORING AND INSPECTION PROCEDURES 1. Groundwater Monitoring Plan A groundwater quality monitoring plan has been prepared separately. The ground and surface water quality will be monitored in accordance with the approved version of that plan. 2. Landfill Gas Perimeter and Interior Monitoring During the decomposition of solid waste, gases are generated and released. Initially, carbon dioxide is the primary gas generated. As more oxygen is consumed by the decomposition, methane is generated in increasing amounts until a steady state is reached in which methane and carbon dioxide are generated in approximately equal amounts. Methane is an odorless and colorless gas produced by the decomposition of organic material. Landfill gas typically consists of 45 to 50% methane by volume. Landfill gas can move through subsurface strata, driven by pressure gradient and dispersion. The primary hazard from methane is its combustible nature. In concentrations of 5% to 15% in air, the mixture is explosive. At concentrations over 15% in air the gas will support a flame. The potential for methane to accumulate in confined spaces to a concentration of 5% or more is a health hazard. Another potential hazard is for the methane and carbon dioxide that frequently accompanies it to displace the ambient air and cause oxygen deficiency. Since methane disperses very quickly, the probability of air displacement is quite remote except in tightly confined spaces. Section 15A NCAC 13B, .1626 (4) requires that the landfill monitor for combustible gas on at least a quarterly basis. The regulatory limits are: 1.25% gas (25% LEL) Interiors of structures 5% gas (100% LEL) Concentration at the property boundary (LEL = Lower Explosive Limit) The landfill has gas monitoring probes installed at the locations shown on the permit drawings. The probes will be monitored according to the following schedule and protocol. a. Landfill Gas Detection A gas detection system is installed around the perimeter of the fill area. The probes are placed at approximately 250' to 300' intervals as shown on drawing sheets 2 and 3, Existing Conditions. In addition, gas will be monitored in structures and confined areas when access is required. All monitoring will be performed in accordance with this Landfill Gas Monitoring subsection. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -9 b. Monitoring Schedule (1) Quarterly for exterior probes with consistent readings of less than 1.25% CH4. (2) Monthly for exterior probes reading over 1.25% CH4. (3) Quarterly for structures. c. Test Equipment Recommendations Exterior probes within a landfill routinely measure two parameters: methane content by percent volume and subsurface pressure in inches of water column. Only methane will be monitored for compliance. Interior testing routinely measures the methane content only. Monitoring for methane can be accomplished with acceptable accuracy with a portable combustible gas meter calibrated for methane. The meter should have a dual scale that reads either 0-5% methane or 0-100% methane. Accessories should include line trap assemblies, sampling hoses, probe tube, spare filters, and spare aspirators or batteries. Subsurface pressure, if monitored, may be measured by a mechanical gauge. A set of at least two gauges will be needed. The recommended pressure ranges are 0-1 inch of water column and 0-10 inches of water column. The gauges come with plastic sampling hoses and aluminum probes. Carrying cases should also be ordered. The gauges are fairly durable if handled properly and require little or no maintenance. If the data collected during routine sampling of the exterior probes is used for design of an active landfill gas control system in the future, then the data should be referenced to atmospheric conditions. Self contained landfill gas monitoring and recording units such as the Gas Data LMSx or Landtec GEM 2000 or GEM 5000 are also recommended. These units can also measure probe pressure. d. Sampling and Analysis Sampling and analytical protocols are specified in this section. (1) Equipment Monitoring instruments will be calibrated in the field to detect the following parameters: methane, carbon dioxide, oxygen. The instruments should be based upon infrared technology, such that methane concentrations are not biased in low- oxygen environments. (2) Perimeter Monitoring Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -10 The gas probes will be inspected upon arrival at each probe. Damaged probes will be repaired or replaced. In the event of settlement around the probe, the area will be regraded and a new concrete apron will be constructed. An IR meter will be used in accordance with the following procedure:  Prepare the appropriate report form with the required information of date, time, atmospheric pressure, probes to be sampled, and location.  Calibrate the meter with the calibration gases.  Clean around the probe cap to keep dirt from entering the sample tubes.  Remove the probe cap.  Connect the meter to the first probe to be measured.  Record peak probe pressure.  Pump until a steady state is reached.  The meter will automatically record the concentrations of methane, oxygen, and other gases, and pressure. Manually record methane concentrations on the report form. Note steady-state pressure.  Disconnect the meter and move to the next probe.  Repeat measurement procedure. After probes have been measured, measure the gas standards using the meter to verify that the calibrations have not drifted. Reports of readings that exceed the regulatory limits will be submitted to the Division upon completion. A copy of reports should be kept at the facility or administrative offices in the official operating record. (3) Interior Monitoring Interior spaces will be monitored using the selected combustible-gas meter in accordance with the following procedures. When personnel are required to fully enter an area to be monitored, oxygen should be monitored prior to methane. If the oxygen content is less than 19.5 percent, the air is considered as oxygen deficient and could be harmful to human health and safety. (a) Oxygen Content Testing  Prepare the oxygen meter by calibrating to ambient air in an open space or outdoors. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -11  At each location tested for methane above, test for oxygen content by inserting oxygen probe.  Pump and read meter after pointer has stabilized.  Test for oxygen levels at approximately one foot above the floor and approximately five feet above the floor.  Record reading on report form. (b) Methane Monitoring  Prepare the appropriate report form noting the date, time, person sampling, etc.  Calibrate the combustible-gas meter and set to 0% on the 0-5% scale. Install the gas sampling hose and probe rod.  Enter the test area in a manner that minimizes the creation of air movements that can disperse methane. If sampling air in a closed space (such as a sewer clean-out), keep the cover closed as much as possible to reduce dispersal of the gas.  Place the probe in the area to be tested. Let the meter pointer stabilize and read the percent gas indicated. If the percent is over 5% remove the probe, switch to the 0- 100% scale and repeat the reading.  Remove the probe and repeat. The readings should be duplicated within 1-2%.  Document readings on the appropriate report form, as well as the location of the test.  Replace covers or caps removed. Specific areas for interior testing are (as applicable per each structure):  sewer cleanouts  pipe penetrations of walls and floors  floor drains - floor grates  confined spaces beneath cabinets and counters  closets and cabinets (especially those near sewer lines)  closed rooms  building foundation vents  floor joints  floor cracks  cracks  pump stations Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -12  manholes  valve vaults If methane readings over 1.25% are recorded, the source should be investigated and the area ventilated. Readings of 5% or greater should be cause for immediate evacuation of the affected area. Begin ventilation immediately and begin a search for the source of the gas. Do not re-occupy until the gas levels are maintained below 1.25%. As a general rule, maintaining a good air flow in the building and good ventilation will help reduce potential gas buildup situations. In addition, areas that are usually closed off such as janitorial closets and equipment service areas can be helped with louvered doors and through-the-wall vents. Reports on interior testing should be transmitted to the reviewing agency immediately upon completion. High readings requiring evacuation or extra ventilation should be reported immediately. e. Action Levels Section .1626(4)(a) of the solid waste rules indicate that the landfill operator must take certain steps when the regulatory limits of gas concentration are reached. Those steps are as follows. (1) Immediately take all steps necessary to protect human health and notify the Solid Waste Division. (2) Within seven days of detection, place in the operating record the methane gas levels detected and a description of the steps taken to protect human health. (3) Within 60 days of detection, implement a remediation plan for the methane gas releases, place a copy of the plan in the operating record, and notify the division that the plan has been implemented. The plan will describe the nature and extent of the problem and the proposed remediation. (4) The Division may establish alternative schedules for demonstrating compliance with Subitem (4) (c) (ii) and (iii). Waiting until the regulatory concentration limits occurs before taking action may accidentally place the site in non-compliance status. Consequently, the following interim action level is recommended. If the exterior probes read 1.25% gas for three consecutive months, the operator will make further investigation in the vicinity of the suspect probes. The investigation will determine if additional monitoring is needed or if additional active gas control devices are needed. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -13 3. Site Evaluations The facility operator must inspect and maintain the closed MSW landfill. A suggested post-closure inspection schedule is provided in the Post-Closure Plan. Inspections are suggested after every major storm event to confirm that excessive erosion or other damage has not occurred; monthly inspections of security control devices and for leachate seeps and repairs made as necessary; and complete inspections of the site made quarterly and repairs made as necessary. Attachment IV-D of the Construction Permit Application (NCDENR Document ID: 6801-MSWLF-1982; Description No: 6821) includes a detailed list of the items that need to be inspected. The list indicates the frequency of the inspections. The list has blank lines to allow the operator to add items as experience dictates. Items on the list pertaining to an active landfill are not applicable to a closed facility. Monthly informal inspections of the active material collection and processing facilities at the site is also recommended to identify housekeeping needs, adequacy of facilities, customer convenience, and efficiency of operations. D. CONTINGENCY PLANNING 1. Wet Weather Operations The County maintains a system of all-weather roads at the facility to allow customers access to all material collection and processing locations at the site during inclement weather conditions. An all- weather access road to the top of the landfill is also maintained for maintenance. 2. Fire Control In accordance with Rule .1626(5)(b) of the Solid Waste Management Regulations, "open burning of solid waste, except for the infrequent burning of land clearing debris generated on site or debris from emergency clean-up operations, is prohibited at all MSWLF units. Such infrequent burning must be approved by the Division." The closure of the MSW landfill with the installation of an active LFG collection system reduces the chance of fires developing within the waste by removing the source of oxygen and providing for the extraction of methane gas. The final cover and LFG system will be periodically inspected to ensure they are functioning as intended. The potential for the development of fires at the facility at the closed landfill or at other locations; however, remains. To provide immediate capability to stop small fires, each piece of equipment is fitted with at least one multi purpose dry chemical fire extinguishers. The fire department can provide training in proper use of fire extinguishers. This training is highly recommended since proper fire extinguisher technique is not obvious and must be learned. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -14 For larger fires the Fire Department should be called. All facility employees should be instructed in the fire fighting techniques. Emergency numbers are listed in the Contingency Plan section of Attachment IV-C in the Construction Permit Application (NCDENR Document ID: 6801-MSWLF-1982; Description No: 6821). This list should be posted in a conspicuous place and updated as needed. The facility operator should review the fire fighting procedures with the fire department to gain their cooperation and to avoid confusion when they arrive at the facility. Authorized representatives of the Fire Department should be provided keys to the entrance gate. They should also be given permission to cut the lock if necessary to gain entry. If fires do occur on the landfill, the Division of Waste Management will be verbally notified within 24 hours of the fire and written notification will be submitted to the Division within 15 days of the occurrence. 3. Hazardous Wastes The closure of the MSW landfill essentially eliminates the potential for hazardous waste to be disposed at the facility. Screening by the scale staff and attendants will verify that unauthorized wastes are not left at the facility. A Household Hazardous Waste Facility has been constructed on- site. It’s operation is addressed under a separate permit. 4. First Aid The use of the facility by customers who may be unfamiliar with the site and the handling of potentially heavy or otherwise dangerous materials could result in accidents leading to injuries. Immediate response is critical to the successful treatment of an injury. At least one person trained in basic first aid should be on the site at all times. It is preferable that at least one person trained in advanced first aid be on the site. These courses are available at a modest cost from the American Red Cross and many rescue squads. An industrial first aid kit should be kept at the office at all times where everyone can find it. Vehicles should have smaller portable first aid kits. The telephone number of the nearest rescue squad should be posted beside every telephone. In addition to first aid, at least one person on duty should have training in Cardiopulmonary Resuscitation (CPR). This training is available from the American Red Cross or the American Heart Association, again at a modest cost. Those who have received training should have it noted in their personnel records. All injuries should be reported and the appropriate reports filed. This will protect the County and the employee in the case of a workman’s compensation claim. It will also give the supervisor a record to check. If the same type of injury keeps reoccurring, then the cause or a method to avoid the injury causing action should be found and changes in procedures made. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -15 5. Leachate Disposal Leachate generated and collected within the closed landfill is discharged directly into the local sewer system via gravity. In the event the local sewer system is shut down for any reason, leachate will be stored in the landfill for no more than 10 working days. If after 10 working days, the local sewer system is still not functional, leachate will be pumped from the landfill through cleanouts at the sump(s) or on-site manholes into a tanker truck for disposal at the local publicly owned treatment works. As soon as the local sewer system is functional, leachate will resume being directly discharge to the sewer system. E. STAFFING 1. Positions The Solid Waste Management Director has overall responsibility for site operations, as well as general site planning. The Director is responsible for policy and field design decisions. The County Solid Waste Management Department is the primary site operator. The County is responsible for the daily activities at the facility. The Director, or his duly appointed representative, will directly supervise and inspect daily operations. The on-site supervisor will administer the daily instructions and be responsible for the proper operation and maintenance of the facilities and equipment. Additional duties may include personnel administration and handling problems with customers. He should also keep the Director up to date on the needs and problems of the facility. The Director and on-site supervisor(s) are the primary contacts for coordination with the University of North Carolina Chapel Hill (University) and its contractors for the operation and maintenance of the Gas Collection and Control system (the “GCCS system”). The Landfill Gas Agreement (the “Gas Agreement”) between the County and the University defines the roles and responsibilities of the parties for all work related to landfill gas management on the landfill. Although the County will retain the ultimate responsibility for compliance, they will rely on the Gas Agreement to fulfill much of their responsibilities for development and daily operations of the GCCS system. Details are provided in the Landfill Gas Management Plan of the Permit Modification dated July 2009 (NCDENR Document ID: 6801-MSWLF-1982; Description No: 8586). The landfill gas engineer for the University has recommended that the GCCS operations staff be trained in the operations and management of landfill gas systems and consult references such as the “Landfill Gas Operation & Maintenance Manual of Practice” prepared by the Solid Waste Association of North America (SWANA) or similar. The County intends to require the University to comply with that recommendation. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -16 Facility attendants are responsible for daily facility servicing and minor maintenance, packaging and removal of collected materials, and other miscellaneous duties such as site clean up. The gate attendants are responsible for handling the incoming vehicles. Vehicles must be processed through the attendant’s station and accurately charged for their waste. Vehicles must be screened and sent to the proper part of the facility for the materials they are carrying. The gate attendants should be familiar with the operational aspects of the facility. They can then give customers accurate answers to their questions about facility rules and policies. Gate attendants assist with other general activities. Occasionally, it may be necessary to add additional staff for special projects such as major cleanup campaigns and construction. Other County staff or part time employees should be considered. 2. Training It is unreasonable to expect any employee to maintain a high degree of skill without periodic training to learn new skills or refresh old skills. Training is available for employees from many sources. Solid waste trade and professional associations sponsor seminars and training at low or no costs. The American Red Cross, Fire Department and National Safety Council can provide first aid, fire and vehicle safety information. Equipment manufacturers are a source of information on equipment operation. The following training program can be implemented at a fairly low cost: Subject Employees Frequency Waste Handling Supervisor, Operators Initial Employment & Annual Equipment O & M Operators Semi-Annual and with all New Equipment First Aid, CPR Safety Coordinator Annual Fire Control All, Fire Department Annual Hazardous Material All Annual Recognizing Hazardous Wastes All Annual General Safety All Operators Monthly, Weekly F. SAFETY 1. General The cost of an accident can be several times the medical expenses required to bring an employee back to work. The personnel working at the facility are exposed to a variety of hazards from heavy equipment, vehicles and the many materials they handle. Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -17 The sources of injury could be fire or explosion, contact with contaminants, falls, equipment accidents, traffic accidents and enclosed areas such as manholes. An effective safety program will train the employees to see the hazards early and avoid them or change the situation to eliminate the hazard. The principle of risk management should be incorporated into daily operations. First, inventory activities to assess hazards. Once the hazards are recognized, determine who is exposed to the hazard and how often the exposure exists. The goal then is to do one of three things. a. Reduce the exposure to the hazard by isolating the hazardous situation or eliminating it. An example may be to place a guard rail next to a steep slope. b. Change the frequency of exposure to the hazard. For example, the servicing of a piece of equipment may be put on a less frequent cycle by use of a higher grade oil or part. c. Where exposure cannot be guarded or reduced the employee must be trained to work in the hazardous environment and give the necessary protective equipment. An example will be the inspection of the leachate collection system. 2. Equipment Most safety training can be accomplished by use of the many packaged training programs. Some equipment manufactures can provide training films that are usually available on a loan basis. The following checklist for safe equipment operation may be useful. a. Check equipment before starting b. Use steps and handholds c. Keep steps clean d. Inspect area before moving e. Operate from driver’s seat f. Wear seat belts g. Never mount moving equipment h. Authorized passengers only i. Keep bucket or blade low j. Check blind areas k. Keep enough clearance l. Avoid sidehill travel m. Avoid excessive speed p. Check work area q. Park on level ground r. Lower attachments to ground when parked s. Never jump from equipment Orange County Landfill Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017 Page IV -18 t. Avoid leaving equipment unattended u. Always have adequate lighting v. Clean equipment before repairing w. Remain in seat during equipment adjustments 3. Personnel Steel toe safety shoes with steel sole plates and gloves should be required apparel for facility personnel. If necessary, dust protection should be provided. Good hygiene should be stressed to all personnel to prohibit the spread of contamination. Smoking on the landfill and in any confined area should be discouraged.