6801_OrangeCo_ClosedMSWLF_Response to Comments_FID1321657__20190529

May 28, 2019 Mr. Ming-Tai Chao Permitting Branch, Solid Waste Section
Division of Waste Management, NCDEQ
217 West Jones Street
Raleigh, NC 27603

RE: Response to 1/17/2019 Review Comments
Orange County Closed Landfill, Permit 68-01
Revised Operations Plan
Draper Aden Associates Project No. R00592-179N

Dear Mr. Chao:

On behalf of Orange County, please find enclosed revised permit amendment documents pertaining
to the Orange County Closed Landfill Operating Plan. These revised documents are submitted for the Section’s
review and approval. Please note that an updated environmental media monitoring plan for each disposal
unit is still currently being generated and will be submitted separately.

Attached you will find each of your comments and our responses in bold. Please feel free to call or email
should we need to discuss further.

Sincerely, Draper Aden Associates

5/28/2019 C. Tyrus Clayton, Jr., PE Team Leader/Senior Associate Attachments: Comment Responses Revised Operations Plan cc: file Robert Williams and Bruce Woody (OCSW) Gordon Dively, PE (DAA)
Page 1 of 5

Response to 1/17/2019 Review Comments
Closed Orange County Landfill, Permit 68-01 Operations Plan
Draper Aden Associates Project No. R00592-179N-2
1. Section B Operations Methods and Procedures
i. 3. Site access, the second paragraph. Signs are posted …, directions to
separate disposal areas for wastes requiring… The landfill units are
closed. The “disposal areas” are misleading.

The term “disposal area” is used in reference to the areas on the site
where the various waste materials are directed for the customer to
dispose of their wastes. There are designated areas on the site that
receive different waste streams such as tires, metal, vegetative waste,
mattresses, etc., which the ensuing paragraph discusses. Additionally,
there is still an active disposal unit on the North side of the site, the
C&D landfill unit that requires site signage to ensure that the
customers are directed to the appropriate area.

ii. 4. Waste Acceptance and Special Waste Handling.
a. Please define the service area – Orange County and its municipalities.
A sentence has been added to the manual to clarify the service area.

b. Please add the citizen waste drop off/household convenience center to
this section.
The convenience center is not part of the landfill facility. It has its
own access and hours of operation. Currently, convenience centers
within the State are not required to be permitted.

Additional language was added to address the use of the existing
HHW facility located on the South side of Eubanks Road.

c. Please provide a drawing to show the overall site plan including the
closure landfill units and all non-disposal units described in Section B.9
of the Operations Plan.
An overall site plan has been added.
Response to 1/17/2019 Review Comments
Orange County Closed Landfill, Permit 68-01
May 28, 2019 DAA PN: R00592-179N
Page 2 of 5

iii. 9. Waste Handling Operations. The following non-disposal units must
provide detailed operation requirements including, but not limited to.
a. Vegetative yard waste collection and processing unit
- No composting shall be conducted at this unit.
- Acreage of the unit.
- Maximum volume at any given day (including processed and unprocessed
wastes).
- The maximum dimensions of each stockpile or windrow. The dimensions
may decrease in the discretion of a Fire Marshal.
- Aisle distance of 25 feet between each stockpile (both processed product
and unprocessed wastes). The distance may increase in the discretion of a
Fire Marshal.
- Requirements for temperature monitoring, moisture control, and turning
of stockpiles to control odors and fires.
- Fire prevention and fighting.
Additional operation information has been added to the document to address the above requested items.

b. Clean wood collection and processing unit.
- No composting shall be conducted at this unit.
- Acreage of the unit.
- Maximum volume at any given day (including processed and unprocessed
wastes).
- The maximum dimensions of each stockpile or windrow. The dimensions
may decrease in the discretion of a Fire Marshal.
- Isle distance of 25 feet between each stockpile (both processed product
and unprocessed wastes). The distance may increase in the discretion of a
Fire Marshal.
- Fire prevention and fighting.
Additional operation information has been added to the document to
address the above requested items.

c. Tire collection unit. (Same comments for Section B.16)
Response to 1/17/2019 Review Comments
Orange County Closed Landfill, Permit 68-01
May 28, 2019 DAA PN: R00592-179N
Page 3 of 5

- Operating a scrap tire collection area shall comply with Rule 15A NCAC
13B .1107.
- Descriptions of the structure for tire collection/storage area – numbers of
covered trailers, the covered structure, or in an open area.
- The tires stored in an open area (as shown on Google map), a plan to
control mosquitoes and rodents to protect the public health and welfare
must be provided.
- Statement of the number of scrap tires stored at a scrap tire collection site
shall not exceed 60,000 tires on site at any time.
- Record keeping requirements.
Additional operational information has been added to the document
to address the above requests. An overall site map has been added, as
request previously, that indicates where the tires are managed on site.

d. Asphalt shingle collection unit.
The SWS has a guidance document to assist facility in management
and process of recycling post-consumer asphalt shingle which can be
downloaded from the web link
https://deq.nc.gov/about/divisions/waste-management/solid-waste-
section/asphalt-shingles
Please complete the required site-specific info in the guidance which
can be appended to the Operations Plan.

The County does not recycle asphalt shingles, at this time, and
does not have any current plans to do so. The mention of that
material has been stricken from the list of services.

e. White goods collection unit.
- Who will remove the Freon from white goods? Does the person have a
state-required license?
- Where the Freon will be stored on-site? What is the maximum quantity of
spent Freon can be stored on-site.
Information about the white goods handling has been added to the
manual.
Response to 1/17/2019 Review Comments
Orange County Closed Landfill, Permit 68-01
May 28, 2019 DAA PN: R00592-179N
Page 4 of 5

f. C&D waste recovery units/activities.
- Description of the C&D waste stream to be recovered as recovered
material as defined in NCGS 130A-290(a)24.
- The maximum quantity of each type of recovered material will be stored at
any given day.
- Dry wall recovered from waste streams must be stored inside a cover
structure and measures to prevent dry wall from saturation must be
implemented in the on-site storage period.
The only waste recovered from the C&D landfill is the bottom metal
frame of any mobile home that is brought to the landfill for disposal.
The frame is extracted from the base of the home and taken over to
the metal pad where it is then placed in a trailer to be hauled off site.

g. A household convenience center (including mattress recycling unit) is
described in Section B.8.
- Please describe the waste streams that are allowed to collect, the
collection storage units/containers.
- Is there an operator (or operators) to conduct waste screening and/or
assist citizen to drop off wastes to the correct containers/units?
- Requirement for signs / placards of waste collection containers.
- Maximum duration that waste can be stored at this unit.
- Transferring collected MSW wastes to a permitted off-site disposal facility.
The convenience center referenced in the quoted section is the Eubanks Road convenience center that is a separate entity from the
solid waste facility. The convenience center has its own entrance and
own hours of operation. It is not intended to be part of the permit.

iv. 9. Waste Handling Operations, the last paragraph. All recyclables or
recovered material must meet the requirements stated in NCGS 130A-
309.05(c).
The regulation has been cited in the operations manual, along with a
brief description of the recycling processing area.

Response to 1/17/2019 Review Comments
Orange County Closed Landfill, Permit 68-01
May 28, 2019 DAA PN: R00592-179N
Page 5 of 5

2. Section E. Staffing.
The County must maintain the current and valid NC air quality permit(s) regulating the
operation, maintenance, and report of the on-site landfill gas collection and control
system.

Noted. The gas collection system is owned and operated by the University of North
Carolina at Chapel Hill (UNCC). The County obtained the necessary solid waste
section permitting, but air permitting was the responsibility of UNCC.
Orange County Landfill – Permit 68-01 Operating Permit Modification - Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019

ORANGE COUNTY LANDFILL
OPERATING PERMIT MODIFICATION

SECTION IV

OPERATIONS PLAN
Orange County Landfill – Permit 68-01
Operating Permit Modification - Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 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 ........................................................... 3 5. Equipment ................................................................................................................... 4 6. Access Roads .............................................................................................................. 4 7. Vehicle Control and Unloading .................................................................................... 4
8. Waste Handling Operations ......................................................................................... 5
9. Surface Water Control ................................................................................................. 9
10. Cleanup Activities ....................................................................................................... 9
11. Vector and Odor Control ............................................................................................. 9
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. ..................................................................................... 10 12. Dust Control .............................................................................................................. 10 13. Erosion Control ......................................................................................................... 10 14. Tires .......................................................................................................................... 11
15. Record Keeping ......................................................................................................... 11
C. MONITORING AND INSPECTION PROCEDURES ...................................................... 12
1. Groundwater Monitoring Plan .................................................................................... 12
2. Landfill Gas Perimeter and Interior Monitoring .......................................................... 12
3. Site Evaluations ......................................................................................................... 17
D. CONTINGENCY PLANNING ........................................................................................... 17
1. Wet Weather Operations ............................................................................................ 17
2. Fire Control ............................................................................................................... 17
3. Hazardous Wastes ..................................................................................................... 18
4. First Aid .................................................................................................................... 18
5. Leachate Disposal ..................................................................................................... 19
E. STAFFING ........................................................................................................................... 19
1. Positions .................................................................................................................... 19 2. Training .................................................................................................................... 20
Orange County Landfill – Permit 68-01
Operating Permit Modification - Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Table of Contents – Page IV-ii

F. SAFETY ............................................................................................................................... 21
1. General ...................................................................................................................... 21 2. Equipment ................................................................................................................. 21 3. Personnel ................................................................................................................... 22 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 – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 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 – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 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 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 drop-off areas and to the Construction and Demolition landfill (Permit 68-04),
information regarding the waste screening program, and other pertinent information.
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -3

4. Waste Acceptance and Special Waste Handling
This facility may accept yard waste, tires, electronics, metals, clean wood, pallets, mattresses, and
white goods from residents and businesses of Orange County and its municipalities, for collection
and recycling or disposal off-site. There are also designated C&D and wood grinding areas on-sites
to be activated for processing disaster debris for disposal off-site.
A permanent HHW Collection Facility is located adjacent to the Inactive/closed South Landfill
Unit. This HHW facility ceased accepting material in August 2018. The facility was inspected
on November 11, 2018 by John Patrone of the North Carolina Department of Natural Resources.
At the time of the November inspection Orange County had not determined what the empty
building would be used for but made clear that the facility would be used for future waste management operations as needed. 1. The County proposes to use this facility as a holding facility for some non-regulated, non-hazardous materials. 2. The County operates two active, permitted, and permanent HHW collection centers. One is located on Walnut Grove Church Road in Cedar Grove, NC and holds Permit No. 68-05. The second facility is located on Eubanks Road in Chapel Hill, NC and holds Permit No. 68-06. The County will use this facility to store paint received from those two HHW facilities. For the latex paint received, it will be processed by mixing it with acceptable solids to dry the paint for transport and disposal to the landfill. For paint not suitable for mixing with solids and landfill disposal, it will be processed for transport and then transported by a licensed hauler to a licensed Treatment, Storage and Disposal Facility.

The County proposes to designate this facility as storage area for paints and household hazardous wastes for short periods of time. HHW material will be stored in this facility in the event that the County’s two HHW Collection Facilities are unable to store materials. An example of this might be during the Spring/Winter Holiday periods when residents in the County are cleaning their homes i.e. “Spring Cleaning.”

HHW will also be stored in this facility during any event that causes delays in
regular transport. For example, following a severe weather event which may
impede safe travel for transport and disposal.
This facility will not be used as a permanent collection facility. The County will remove any excess/emergency amounts of HHW as soon as reasonably possible not to exceed 30 days.

Materials accepted at the facility will be directed to special handling areas.
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -4

An overall site plan is included at the end of the Operation Plan.

5. 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.
6. 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
7. Vehicle Control and Unloading
Customers entering the facility will be controlled by the operations staff using the following
procedures:
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -5

a. Eliminate traffic that does not need to go to the facility. A separate household convenience
center is provided on the north side of Eubanks Road, east of the landfill facility, for use by
County 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.
8. Waste Handling Operations
The facility maintains the following services:
• a landfill gas collection system,
• collection and processing of vegetative waste,
• mulching of separated yard waste and clean wood waste, and sale of mulch and compost,
• tire collection for recycling,
• collection of metal 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 temporary storage(discussed above in Section 4),
All materials are removed from the facility by the County or vendors. No materials are permanently
disposed at the facility.
Landfill Gas Collection System – The University of North Carolina at Chapel Hill (UNCC) owns
and operates the gas collection and conveyance system at the closed landfill units. UNCC performs
the weekly and monthly gas monitoring and system maintenance and adjustments. The collected
gas is either flared on-site or transmitted off-site to gas powered electric generator that produces
electricity that is sold to the poser supply company. Per the lease agreement between the County
and UNCC, UNCC is responsible for all of the maintenance, operation and permitting requirements
for the system.
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -6

Access to the system and its components is controlled by fencing to prevent unauthorized personnel
from adjusting the system. UNCC has a remote site that monitors the performance of the system
and alerts the County of any issues that arise.

Clean Wood and Vegetative Waste Processing- The County collects clean wood and vegetative
waste at the facility and them grinds the two products making boiler fuel and mulch, respectively.
Both materials are handled in a similar manner. The following process shall apply to both unless
noted otherwise.
The materials are co-located in an area approximately 3.1 acres in size. Materials are dropped off by
customers on the southern half of the area where they are stored until a sufficient amount of material
has accumulated for efficient grinding operations. Materials are placed into windrows with
maximum dimensions of 50 feet wide, 12 feet high and 260 feet long. A 25-foot wide access way is
maintained between windrows to facilitate fire control. The maximum amount of material that the
site can store is approximately 18,000 cubic yards.
Producing a highly quality mulch that citizens want requires proper treatment to ensure that the
outgoing product will not create an excessive number of weeds. Many people apply mulch to
prevent weeds in flower gardens, so introducing weed seeds is counter-productive. The process for
treating mulch is very similar to making compost, where controlling temperature and moisture is
essential. The County, however, does not produce compost. Due to the nature of the earth products,
though, it is possible for finer textured material to form during the entire process that will give the
appearance of compost, but the material has been managed so that it has not been through the
time/temperature cycle needed for composting.
Grinding of material happens on the western side of the processing area and finished product is sold
from the eastern side. Ground material is managed so that the internal temperature of the pile does
not exceed 132 degrees Fahrenheit. The processed material windrows are turned once temperatures
reach that temperature, but no longer than typically 30 days. The turning process moves material
from west to east in the processing area so that the oldest material is sold first. The temperature
range is watched carefully to balance the ability to kill weed seed and not have the pile
spontaneously combust.
In the event of a fire, the onsite equipment can be used to isolate the fire and either snuff it out or
spread it out on the paved area. The County also maintains a water truck on site that is kept loaded
with water that can be used to extinguish a fire, or to wet down hot spots that have been put out by
other mechanical means. The site is served by the New Hope Volunteer fire department. In the
event of a fire, the operator should notify his supervisor immediately. The supervisor will be
responsible for documenting the event, researching the cause, and reporting the incident to DEQ.
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -7

When temperatures are being checked, the operator should also check the moisture of the mulch
using the “hand/roll” technique. This process requires the operator to grab a handful of material
from the inside of the mulch pile and compress it into a ball. If water squeezes out, the pile is too
wet, if it falls apart immediately, it is dry, and if there is a slightly moist feel to it or if it maintains a
slight clump, the moisture level is appropriate.
Clean wood waste is monitored in much of the same manner, except that it rarely lasts long enough
to be turned. The processed clean wood, or boiler fuel, is typically produced in the southwest corner
of the processing area and loaded into customers trailers using either a conveyor located adjacent to
the pile, or with a loader. Mulch is loaded into customers vehicles or trailers using a 3-cubic yard
loader.
Scrap Tires – Scrap tires are collected and temporarily stored just west of the entrance to the facility
on the north side of Eubanks Road. In the past, two different methods for handling the tires have
been used by the outside vendors that the County contracts with to dispose of the tires. Under the
current methodology, the vendor keeps a backhoe with a grappling attachment on site and brings in
trailers when tires need to be loaded and hauled off site.
The backhoe is located directly adjacent to the loading platform where the trailer is backed up
against. Customers drop off their tires next to the backhoe, and as the pile grows, tires are dropped
off further away from the loading platform. County staff use loaders that are onsite for other various
functions to push the tires forward to the loading platform. The backhoe loads the tires closest to it
and works its way outward from the loading platform. This process ensures that the oldest tires
onsite are loaded first. Tires are loaded onto trailers and removed from the site three to four times a
week.
The other method that has been used and may be available to the County at some point in the future
is having trailers onsite that are loaded by the vendor three times a week. Under this scenario, three
trailers were typically kept on site, and swapped out after they had been loaded. The tires are
managed in the same manner as discussed above, expect a laborer is used to hand load the tires into
the covered trailers. The laborer will work from the tires closest to the loading platform and work
his out. A County operator will push the pile forward towards the loading platform as needed.
Per 15A NCAC 13B.1107, the maximum size of the pile shall not exceed 200 feet in length, 50 feet
in width and 15 feet in height and the maximum number of tires permissible on site is 60,000. The
County stores the tires on a concrete pad that is approximately 50’ by 50’ which is well below the
maximum pile size prescribed by the regulations.
Because most tires are removed from the site after only a few days, issues with mosquitos and
rodents have not been experienced. However, County staff does monitor the tire pile to ensure that
vectors do not become a problem. In the event that vectors are present, the County has contracts with
outside pest control vendors that are used to limit their activity.
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -8

All loads containing tires are weighed in at the scale house and the loaded trailers that are being
removed by the tire vendor are weighed out. The tickets are kept for record keeping purposes.
White Goods and Scrap Metal – The County receives white goods and metal at the solid waste
facility in two different piles on a concrete pad that is approximately 80’ deep and 130’ long. The
pad was constructed with a push wall and grade separation so that trailers can be loaded from the
high side using a backhoe that is dedicated to the metal area.
The County currently employs multiple staff members that are licensed to remove refrigerant from
appliances containing such. The extraction system used by the County is connected to a ten-pound
tank that collects the freon. Quantities recovered from the disposed appliances is typically small and
takes several months to fill a tank. Once the tank has reached or is near capacity, the County
contacts their household hazardous waste vendor to collect the container.
The tank and extraction equipment are kept in a locked metal building located adjacent to the metal
collection pad. The licensed removal personnel keep a log of the appliances and the amount of
refrigerant that was collected. Once the refrigerant has been removed, the appliances are then
placed in the trailer to be hauled to a scrap metal yard.
Scrap metal is also collected and loaded into a trailer at this location to be shipped to a scrap metal
yard for processing. The metal is typically dropped off by customers or comes from the C&D
landfill where operators will remove the metal base frame of mobile homes that have been brought
in for disposal. An operator is stationed near the metal pad and inspects each load that is dropped
off.
Electronics – A metal building located on the south side of Eubanks Road, east of the closed South
MSW unit is used for collecting and processing electronic equipment for recycling. Materials are
brought to the building from their collection point and sorted by like components. The material is
then palletized, shrink wrapped and loaded onto a trailer located near the building. Once the trailer
is full, typically weekly if not sooner, it is hauled off site by the current electronic recycling vendor
employed by the County.
Recycling Pad- The County operates a recycling processing pad in accordance with NCGS 130A-
309.05 (c) where recyclable materials are brought to be inspected and processed for market. The
majority of incoming recyclables come from single stream collection efforts throughout the County.
These materials are dumped onto the pad where a loader operator pushes up the material for loading
into ta trailer that will transport the material to a Materials Recovery Facility for processing. While
the operator if pushing the material, he is also observing the material for contamination that needs to
be removed from the recycling stream. Contaminants that are removed are placed in a small front
load dumpster that is placed near the pad. The dumpster is emptied daily or every other day by
County staff and taken to the transfer station for disposal.
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -9

The County also operates a baler that is used to palletize large rigid plastics for transport and sale to
secondary markets. The materials are dumped onto the recycling pad floor and loaded with a small
skid steer into the hopper for the baler. During the loading process, the operator is observing the
material for contaminants that need to be removed and disposed of properly. Baled plastics are then
loaded into an enclosed trailer, and once full, the trailer is taken to the receiving processing facility.
9. 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.

10. Cleanup Activities
During the day to day operation of the facility, debris will be spilled on the roads, litter will blow
from the collection areas, mud will accumulate in the ditches, and the dirt will be tracked on the
roads. These are unavoidable circumstances and are common to all waste 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.
11. 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 – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -10

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.
12. 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.
13. 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.
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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.
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.
14. Tires
Whole tires are collected at the facility from customers and are currently being removed from the
site by a private contractor.
15. 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 – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -12

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 – Permit 68-01 Operating Permit Modification – Operations Plan
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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
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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.
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July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -15

 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
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 pump stations
 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.
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The investigation will determine if additional monitoring is needed or if additional active
gas control devices are needed.
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
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -18

proper use of fire extinguishers. This training is highly recommended since proper fire extinguisher
technique is not obvious and must be learned.
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.
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
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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.
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
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Page IV -20

(SWANA) or similar. The County intends to require the University to comply with that
recommendation.
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:
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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.
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
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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
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.
Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan
July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019 Figure

FIGURE
OVERALL SITE PLAN
CLOSED ORANGE COUNTY
LANDFILL UNIT
1 inch = ft.
( IN FEET )
GRAPHIC SCALE
0100 100 200
100
50
CLOSED ORANGE COUNTY
LANDFILL UNIT
1 inch = ft.
( IN FEET )
GRAPHIC SCALE
0100 100 200
100
50
EUBANKS
ROAD
C & D
LANDFILLPHASE I
ACTIVE
CLOSED ORANGE
COUNTY SOUTH
MSW LANDFILL
(PERMIT 68-01)
EUBANKS
ROAD
C & D
LANDFILLPHASE I
ACTIVE
515
515
510
510
505
505
500
500
495
495
490
490
485
485
480
480
475
475505
520
519
518
517
516
516517518
519520
DESIGNED BY:
DRAWN BY:
CHECKED BY:
SCALE:
DATE:
PROJECT NUMBER:
REVISIONS
P:\R00\500\R00592\R00592-179N\CAD\R00592-179N\R00592-179N_EXISTING.dwg May 28, 2019 5:57:56 PMR00592-179N
JUNE 23, 2017ORANGE COUNTY EUBANKS ROAD C&D LANDFILLPERMIT 68-04 RENEWALORANGE COUNTY, NORTH CAROLINADraper Aden AssociatesEngineering Surveying Environmental ServicesNorthern VirginiaFayetteville, NCHampton Roads, VABlacksburg, VARichmond, VACharlottesville, VANCSU Centennial Campus930 Main Campus Drive, Suite 151Raleigh, NC 27606919-827-0864 Fax: [phone]www.daa.comNC Firm License # C-086105/15/19 - RESPONSE TO
NCDEQ REVIEW
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2OVERALL SITE PLAN480
LEGEND
From:Tyrus Clayton
To:Chao, Ming-tai
Cc:Bruce Woody; Stanley, Sherri; Gordon Dively
Subject:[External] RE: Comments on Operations Plan_closed Orange County Landfill Post-closure land use, 6801, FID1275717
Date:Wednesday, May 29, 2019 1:47:10 AM
Attachments:image001.jpgimage005.pngimage002.jpgimage004.png
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]
Ming,

Below is a link to our response to the 1/17/2019 comments and revised Operational Plan for the
Closed Landfill Permit No. 68-01. Should you require hard copies, please let us know.

https://files.daa.com/dl/pCaSe3itxM

Please feel free to call or email should we need to discuss further.

Sincerely,

C. Tyrus Clayton, Jr., PEGeotechnical/Construction Services Team LeaderSenior Associate Draper Aden Associates
Engineering • Surveying • Environmental ServicesLasting     Positive     Impact™ Phone: [phone] • Direct Line: 919.827.0909 • Mobile [phone]
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From: Chao, Ming-tai <[e-mail]>
Sent: Thursday, January 17, 2019 9:06 AM
To: Gordon Dively <[e-mail]>
Cc: Bruce Woody <[e-mail]>; Tyrus Clayton <[e-mail]>; Stanley,
Sherri <[e-mail]>
Subject: Comments on Operations Plan_closed Orange County Landfill Post-closure land use, 6801,
FID 1275717

Dear Mr. Dively: The Solid Waste Section completes a review of the Operations Plan (FID 1274688) for the non-
disposal units at the closed Orange County Regional Landfill (North Unit/Phase 1). Comments on
the Operations Plan are stated below:

FID12757171. Section B Operations Methods and Procedures
i. 3. Site access, the second paragraph. Signs are posted …, directions to
separate disposal areas for wastes requiring… The landfill units are closed. The “disposal areas” are misleading.
ii. 4. Waste Acceptance and Special Waste Handling.
a. Please define the service area – Orange County and its municipalities.
b. Please add the citizen waste drop off/household convenience center to this
section.
c. Please provide a drawing to show the overall site plan including the closure
landfill units and all non-disposal units described in Section B.9 of theOperations Plan.
iii. 9. Waste Handling Operations. The following non-disposal units must providedetailed operation requirements including, but not limited to.
a. Vegetative yard waste collection and processing unit
- No composting shall be conducted at this unit.
- Acreage of the unit.
- Maximum volume at any given day (including processed and unprocessedwastes).
- The maximum dimensions of each stockpile or windrow. The dimensions maydecrease in the discretion of a Fire Marshal.
- Isle distance of 25 feet between each stockpile (both processed product andunprocessed wastes). The distance may increase in the discretion of a FireMarshal.
- Requirements for temperature monitoring, moisture control, and turning ofstockpiles to control odors and fires.
- Fire prevention and fighting.

b. Clean wood collection and processing unit.
- No composting shall be conducted at this unit.
- Acreage of the unit.
- Maximum volume at any given day (including processed and unprocessed
wastes).
- The maximum dimensions of each stockpile or windrow. The dimensions may
decrease in the discretion of a Fire Marshal.
- Isle distance of 25 feet between each stockpile (both processed product and
unprocessed wastes). The distance may increase in the discretion of a FireMarshal.
- Fire prevention and fighting.

c. Tire collection unit. (Same comments for Section B.16)
- Operating a scrap tire collection area shall comply with Rule 15A NCAC 13B.1107.
- Descriptions of the structure for tire collection/storage area – numbers ofcovered trailers, the covered structure, or in an open area.
- The tires stored in an open area (as shown on Google map), a plan to controlmosquitoes and rodents to protect the public health and welfare must beprovided.
- Statement of the number of scrap tires stored at a scrap tire collection site shallnot exceed 60,000 tires on site at any time.
- Record keeping requirements.

d. Asphalt shingle collection unit.
The SWS has a guidance document to assist facility in management and
process of recycling post-consumer asphalt shingle which can bedownloaded from the web link
https://deq.nc.gov/about/divisions/waste-management/solid-waste-section/asphalt-shingles
Please complete the required site-specific info in the guidance which can beappended to the Operations Plan.

e. White goods collection unit.
- Who will remove the Freon from white goods? Does the person have a state-required license?
- Where the Freon will be stored on-site? What is the maximum quantity ofspent Freon can be stored on-site.

f. C&D waste recovery units/activities.
- Description of the C&D waste stream to be recovered as recovered material asdefined in NCGS 130A-290(a)24.
- The maximum quantity of each type of recovered material will be stored at anygiven day.
- Dry wall recovered from waste streams must be stored inside a cover structureand mesures to prevent dry wall from saturation must be implemented in the
on-site storage period.
g. A household convenience center (including mattress recycling unit) isdescribed in Section B.8.
- Please describe the waste streams that are allowed to collect, the collectionstorage units/containers.
- Is there an operator (or operators) to conduct waste screening and/or assistcitizen to drop off wastes to the correct containers/units?
- Requirement for signs / placards of waste collection containers.
- Maximum duration that waste can be stored at this unit.
- Transferring collected MSW wastes to a permitted off-site disposal facility.
iv. 9. Waste Handling Operations, the last paragraph. All recyclables or
recovered material must meet the requirements stated in NCGS 130A-309.05(c).

2. Section E. Staffing.
The County must maintain the current and valid NC air quality permit(s) regulating the
operation, maintenance, and report of the on-site landfill gas collection and controlsystem.
Please respond the comments which should be incorporated into the revised Operations Plan. If you have any questions please contact myself. Thanks.

From: Gordon Dively [mailto:[e-mail]]
Sent: Wednesday, January 09, 2019 9:59 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Bruce Woody <[e-mail]>; Tyrus Clayton <[e-mail]>
Subject: [External] Orange County Permit Renewal

CAUTION: External email. Do not click links or open attachments unless you verified. Send all suspicious email as an
attachment to [e-mail]

Ming,

Included below are links to the requested documents for Orange County. Please let me know if you
have any issues downloading the two.

Here is the link to the Operations Plan for the Closed Landfill, Permit Number 68-01 (DAA PN
R00592-00):

https://files.daa.com/dl/1iZgURzw3d

Here’s the link for the active C&D Landfill, Permit Number 68-04 (DAA PN R00592-179N):

https://files.daa.com/dl/FIrbmurZf0

Thank you,

Gordon Dively, PESenior Engineer Draper Aden Associates
Engineering • Surveying • Environmental ServicesLasting     Positive     Impact™ Office: 919.827.0864 · Mobile: [phone]

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