4112_WhiteStreetMSWLF_CityResponsetoIncompletenessDetermination_FID1386797_20191206

GREENSBORO
NORTH CAROLINA
�
December 6, 2019 '���f v fo
Ms. Sherri Stanley DEC 13 Z01g
North Carolina Department of Environmental Quality 1t�N
Solid Waste Section W 41 act
Permitting Branch Head Spl-IID
Raleigh Central Office
1646 Mail Service Center
Raleigh, NC 27699-1646
RE: PERMIT RENEWAL APPLICATION FOR PERMIT # 41-12
Ms. Stanley:
On September 13, 2019, the City of Greensboro (City) had successfully submitted the permit
renewal application for Phase III at the White Street Landfill (Permit # 41-12). As required, the
City submitted the renewal application more than six months before the expiration of the existing
permit (April 2020). In order to be as responsive to North Carolina Department of Environmental
Quality (NCDEQ) requests, the City has responded to previous informational requests via e-mail.
It is our hopes that this latest request will provide the last piece of information required by
NCDEQ regulations, and the NCDEQ can now continue with their review and approve the
permit renewal request.
The last e-mail request from information from Mr. Chao dated November 26, 2019 requested a
response to the following:
The Solid Waste Section stays firm with the decision made in the inspection report dated
September 10, 2019 that the City of Greensboro shall submit the requested documents
stated in items #26 & 36 of the inspection report; otherwise, the permit application (FID
1358029) that was received on September 13, 2019 is considered as an in -completed
one. We are looking forward to receiving the requested documents.
In order to completely address the NCDEQ's latest request, I have included the specific items
from the Facility Compliance Inspection Report (attached).
26. The facility is permitted to co -dispose of wastewater treatment sludge (WWTS)
generated within its approved service area. Only WWTS is disposed of in Cell 3 at this
time. Co -disposal of WWTS is not currently conducted.
640
PO BOX 3136 • GREENSBORO NC 27402-3136 • WWW.GREENSBORO-NC.GOV • 336-373-CITY (2489)

36. The facility is permitted to receive solid waste from Guilford County. Currently the
facility is only receiving sludge from the TZ Osborne wastewater treatment plant. Site is
not receiving MSW waste except in emergency situations.
The City acknowledges the NCDEQ inspector's observations stated in items # 26 & 36 of the
inspection report. Items 26 and 36 do not specify what documentation is required; however, the
City has provided clarity through previous email correspondence (dated November 26, 2019,
attached) and this letter in response to the statements made by NCDEQ. The City would also
like to clarify that sludge and incinerator ash are co -disposed at this site. We are currently
receiving incinerator ash and sludge from TZ Osborne Wastewater Treatment Plant and have the
potential to receive additional MSW from projects approved by Council or as an emergency
backup to the Transfer Station operations. The City believes we have provided NCDEQ the
clarity required in addition to the complete permit application to begin your review of our permit
renewal application.
The City hopes that this response and the previous responses included in the November 26, 2019
email chain have completely satisfied the NCDEQ request for information. Should you need
additional information, please provide those requests in writing to Mr. Richard P. Lovett, our
Environmental Compliance Manager overseeing the permit renewal process.
Sincerely,
D. Dale Wyr , P.E.
City of Greensboro
Director of Field Operations
Attachments: 1. Facility Compliance Inspection Report (dated September 10, 2019)
2. November 26, 2019 email exchange
cc: Chris Marriott, Deputy Director of Field Operations
Richard P. Lovett, Environmental Compliance Manger
James Dickens, City Attorney
Mike Plummer, P.E., HDR

FACILITY COMPLIANCE INSPECTION REPORT
, RE Division of Waste Management
Solid Waste Section
UNIT
TYPE:
Lined
MSWLF
X
LCID'
YW
Transfer
Compost SLAS COUNTY: Guilford
T&P FIRM PERMIT NO.: 41-12
DEMO sDTF FILE TYPE: COMPLIANCE
Closed
MSWLF
1u3w
white
oods
mein
cDLF
TireT&P!
Tire
Industrial
Collection
Monofill
Landfill
Date of Site Inspection: September 10, 2019
FACILITY NAME AND ADDRESS:
City of Greensboro MSW Landfill — White Street Landfill
2503 White Street
Greensboro, NC 27405
GPS COORDINATES: Lat.: 36.10454 Long.:-79.73018
FACILITY CONTACT NAME AND PHONE NUMBER:
David Deel, Solid Waste Disposal Manager
w. 336-412-3959
c. 336-382-8366
david.deel��7a. izreensboro-nc.go<-
FACILITY CONTACT ADDRESS:
City of Greensboro Field Operations Department
David Deel, Solid Waste Disposal Manager
2503 White Street
Greensboro, NC 27405
Date of Last Inspection: November 13, 2017
PARTICIPANTS:
Chuck Kirchner, Environmental Senior Specialist — Solid Waste Section (SWS)
David Deel, Solid Waste Disposal Manager — City of Greensboro Field Operations Department
Richard P. Lovett, Environmental Compliance Support Manager — City of Greensboro Field Operations Department
Lewis S. Walker, Jr., Landfill Compliance Supervisor - City of Greensboro Field Operations Department
Anna Stoddard, Environmental Compliance Specialist - City of Greensboro Field Operations Department
Tim Summers, Compost Manager - City of Greensboro Field Operations Department
STATUS OF PERMIT:
Permit to Operate (PTO) issued June 11, 2015
PTO Expiration date April 14, 2020
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS•
None
OBSERVED VIOLATIONS:
None
Page 1 of 4

�r
FACILITY COMPLIANCE INSPECTION REPORT
Q_E Q,� Division of Waste Management
�Solid Waste Section
The item(s) listed above were observed by Section staff and require action on behalf of the facility in order to come into or maintain compliance
with the Statutes, Rules, and/or other regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22, an
administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid Waste Laws, Regulations, Conditions of a Permit,
or Order under Article 9 of Chapter 130A of the N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to
enforcement actions including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and any
such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.
ADDITIONAL COMMENTS
On September 10, 2019 Chuck Kirchner with the Solid Waste Section met with David Deel, Richard Lovett, Lewis
Walker and several other members of the City of Greensboro Solid Waste Department to conduct a comprehensive
inspection of the White Street MSW landfill.
Facility Information:
I. The City of Greensboro operates a municipal solid waste (MSW) landfill (Phase III, 41-12). The property also
contains a large type I solid waste compost (SWC) facility (41-03), a construction and demolition debris (C&D)
atop a closed MSW landfill (Phase 11, 41-03) adjacent to a closed unlined MSW landfill (Phase 1), and a
temporary disaster debris staging site (TDDSS, DS41-002).
2. The facility is open Monday through Friday 7:50 am to 4:50 pm and Saturday 7:00 am to 1:00 pm.
3. The facility is permitted to receive solid waste generated within the City of Greensboro and Guilford County.
4. The MSW landfill is permitted to operate Phase III, Cells 1, 2 and 3.
5. The facility does not accept scrap tires or white goods.
6. The MSW landfill Cells 1 and 2 contain intermediate soil cover and have a good grass cover.
7. Waste is currently being placed in Cell 3.
Records Inspection:
8. The facility site plan, permit and operations plan were discussed.
9. The following employees are certified landfill managers:
a. David Deel, Certified Manager of Landfill Operations, certification No. 93440, exp. 03/26/21
b. Lewis S. Walker, Jr., Certified Manager of Landfill Operations, certification No. 54260, exp. 06/26/21
c. John Bald, Landfill Operations Specialist, certification # LF-2009087, exp. 12/4/2021
d. Eddie Briggs, Jr., Landfill Operations Specialist, certification # LF-2018012, exp. 2/22/2021
e. Ronnie Bullins, Jr., Landfill Operations Specialist, certification # LF-2018009, exp. 2/23/2021
f. Bernard Garner, Landfill Operations Specialist, certification # LF-2011072, exp. 2/22/2021
g. Dustin L. Gordon, Landfill Operations Specialist, certification # LF-2015012, exp. 3/24/2021
h. Timothy M. Graham, Landfill Operations Specialist, certification # LF-2015013, exp. 3/24/2021
i. Michael Jordan, Landfill Operations Specialist, certification # LF-2014003, exp. 2/22/2021
j. Tony McKinney, Landfill Operations Specialist, certification # LF-2018008, exp. 2/23/2021
k. Andrew Subotnik, Landfill Operations Specialist, certification # LF-2018005, exp. 2/23/2021
1. Timothy Summers, Landfill Operations Specialist, certification # LF-2018006, exp. 2/23/2021
m. Donald L. Van Eaton, Landfill Operations Specialist, certification # LF-2011081, exp. 2/22/2021
10. The facility maintains daily and monthly records of the amount of solid waste received. F a c i 1 i t y r ecords
were observed for January 1, 2018 through September 10, 2019. The facility received 12,884.42 tons of
waste during that timeframe.
11. The facility annual report (FAR) dated July 31, 2019 was received by the SWS. Facility records for July 2018
through June 2019 is 7,533.14 tons which is approximately up 1000 tons since 2018 FAR and down 25,000 tons
since 2017 FAR.
12. The facility maintains a daily leachate inspection sheet that logs external tank condition, leachate tank gauge
operation, gallons of leachate pumped, pump -down times, rain gauge totals, etc. Records were not observed
this inspection.
13. The leachate collection lines are required to be remote camera inspected every five years. The leachate
collection trunk lines were last camera inspected by Jetclean America on February 3, 2017.
Page 2 of 4

FACILITY COMPLIANCE INSPECTION REPORT
M1Cq'31 �:AgLY. I1JA Division of Waste Management
5P .. apa+Vo�d of En:{w�nmYl WYiI�
Solid Waste Section
14. The facility conducts methane monitoring at 13 methane monitoring wells and at the scale house and
operations building. Landfill gas monitoring wells 2-5, 7 and 10 were observed this inspection and the wells
are maintained in an accessible condition.
15. The facility maintains quarterly methane monitoring records. Methane monitoring is conducted by facility
personnel. Records were observed for March 18, 2018 (1st quarter), June 8, 2018 (2' quarter), September
20, 2018 (3rd quarter), December 17, 2018 (4t' quarter), March 25, 2019 (1st quarter) and June 13, 2019 (2nd
quarter). No exceedance of the methane lower explosive limit (LEL) is noted.
16. The facility uses two GEM5000 gas analyzer units to conduct quarterly methane monitoring. Gas analyzer
unit calibration records were observed, conducted on August 24, 2017 and October 17, 2016. Mr. Walker
stated that this unit has been upgraded to test for hydrogen sulfide (1-12S). Ensure results for H2S sampling
are recorded on quarterly logs.
17. Groundwater wells, 9- 11, 15, 17-25 and 25D were observed during this inspection and were maintained in an
accessible condition.
18. The facility maintains semiannual groundwater and surface water monitoring and leachate test records that
had been submitted by S&ME, Inc., currently submitted by Golder Associates NC, Inc., and analyzed by
Environmental Conservation Laboratories, Inc. (ENCO). Records were observed for groundwater and
surface water monitoring and leachate testing conducted on September 14, 2018, February 22, 2019 and
August 14, 2019 an exceedance was indicated on all three reports.
Facility Inspection:
19. Leachate from Phase III Cells 1, 2, and 3 drain into a leachate manhole before being routed to the leachate
storage tanks. During the inspection, the leachate manhole was observed and appears in good condition.
20. The facility has two 350,000-gallon leachate storage tanks with a secondary containment wall. Leachate is
generally maintained in tank A. During the inspection, the leachate level in Tank A was 9.6 feet and Tank
B was 4 feet. The leachate tanks are usually pumped down to the sanitary sewer when the leachate level
reaches 18-19 feet in Tank A. According to facility staff the tanks will also be pumped down in anticipation
of a large storm event. The leachate tanks are connected by spillover pipe and can be pumped from one to
the other.
21. The leachate storage tanks are connected to the City of Greensboro sanitary sewer which flows to the TZ Osborne
wastewater treatment plant where the wastewater treatment sludge disposed of at facility originates.
22. The facility [Phase III] has a landfill gas collection system. The landfill gas pipeline to Cone Mills has been
capped and is no longer used as boiler fuel. All landfill gas from the Phase IIl area is flared off. The landfill
gas flare was observed in operation.
23. The facility is permitted to use Posi-Shell. Mr. Walker stated that only soil cover is used at this time.
24. The MSW landfill Cells 1 and 2 contain intermediate soil cover.
25. The facility is permitted for leachate recirculation. Mr. Lovett stated that leachate recirculation is not
currently conducted.
26. The facility is permitted to co -dispose of wastewater treatment sludge (WWTS) generated within its
approved service area. Only WWTS is disposed of in Cell 3 at this time. Co -disposal of WWTS is not
currently conducted.
27. Adequate soil was observed around the working face for use as cover material.
28. Currently the facility receives about four loads a day of wastewater treatment sludge generated from the TZ
Osborne Wastewater Treatment Plant.
29. The landfill cap contained vegetative cover and appeared maintained.
30. A good grass cover was observed in many areas around Phase Ill. Erosion and sedimentation controls appeared
to be in good order.
31. The facility has installed edge of waste markers. Facility staff said there were plans to replace edge of waste
markers soon.
32. During the inspection odor was not detected.
33. Landfill cap was being mowed during inspection and appears to be well maintained.
34. Windblown material was not observed.
35. The facility has a water truck available for dust control.
Page 3 of 4

FACILITY COMPLIANCE INSPECTION REPORT
ME �; > Division of Waste Management
Solid Waste Section
General Comments:
36. The facility is permitted to receive solid waste from Guilford County. Currently the facility is only receiving
sludge from the TZ Osborne wastewater treatment plant. Site is not receiving MSW waste except in emergency
situations.
37. On January 5, 2015, the facility was issued a Division of Air Quality (DAQ) Title V permit No. 08830T08,
expiration date December 31, 2019.
38. The facility has a stormwater National Pollutant Discharge Elimination System (NPDES) permit, General
Permit No. NCG120000, Certificate of Coverage No. NCG120013. The NPDES permit expires on September
30, 2022.
39. The facility has proper signage.
40. Access roads are of all-weather construction.
41. The facility is secured by a locked gate.
42. Mr. Lovett stated that in the event of an emergency the facility will call 911 for assistance.
43. The PTO expiration date is April 14, 2020.
44. The PTO renewal application for life of site operations was submitted to the SWS om September 13, 2019. The
facility is currently operating under City Council approval for a limited waste stream (type and volume)
for the current 5-yr permit expiring in April 2020. As part of the permit renewal process, please be
prepared to provide authorization from Council for the continued operation of the landfill for the next 5
years. A permit condition will be added to require future confirmation of council at least once per 5 years.
45. In addition, please be prepared as part of the permit renewal process to provide information related to the
phasing or filling of the landfill, stability of the waste mass over time, etc. similar to previous requests at
the time of permitting. Specifically, the 2015 renewal contained information for waste volumes based on
known waste streams during the Syr permit of no more than 100,000 tons of waste. Since the waste volumes
since 2017 have been below 10,000 tons annually, the approved drawings may not accurately indicate
current and proposed future operations should those volumes remain similar to the last 3 years.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Chuck
L w` Kirchner
Date: 2019.09.2416:50:10
-04'00' Phone: [phone]
Chuck Kirchner
Environmental Senior Specialist
Regional Representative
Sent on: September 24, 2019 �X T_ Email
Hand delivery US Mail Certified No. "
Copies: Deb Aja, Western District Supervisor - Solid Waste Section
Sherri Stanley, Permitting Branch Head — Solid Waste Section
Lewis Walker, Landfill Compliance Supervisor — City of Greensboro, Lewis.WalkerC r� eensboro-nc.gov
Richard Lovett, Environmental Compliance Support Manager — City of Greensboro,
Richard.Lovett eensboro-nc. ov
Anna Stoddard, Environmental Compliance Specialist — City of Greensboro,
Anna. Stoddard. eensboro-nc. gov
Page 4 of 4

2,
Lovett, Richard
From: Chao, Ming-tai <[e-mail]>
Sent: Tuesday, November 26, 2019 3:56 PM
To: Lovett, Richard
Cc: Wyrick, Dale; Dickens, James; Marriott, Chris; Plummer, Michael; Stanley, Sherri; Watkins,
Jason; Kirchner, Chuck; Mussler, Ed
Subject: RE: [External] White Street Phase III permit renewal
Attachments: ATT00001.txt
Follow Up Flag: Follow up
Flag Status: Flagged
Dear Mr. Lovett:
Thank you for providing information of the White Street MSWLF (Phase 3), Permit # 4112-MSWLF-
1997. The Solid Waste Section stays firm with the decision made in the inspection report dated September 10,
2019 that the City of Greensboro shall submit the requested documents stated in items # 26 & 36 of the
inspection report; otherwise, the permit application (FID 1358029) that was received on September 13, 2019 is
considered as an in -completed one. We are looking forward to receiving the requested documents.
Regards,
E
NORTH CAROUNA
Oeparlment of Environeiental pual�
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Lovett, Richard <[e-mail]>
Sent: Tuesday, November 26, 2019 1:55 PM
To: Chao, Ming-tai <[e-mail]>
Cc: Wyrick, Dale <[e-mail]>; Dickens, James <][e-mail]>; Marriott,
Chris <[e-mail]>; Plummer, Michael <[e-mail]>; Stanley, Sherri
<[e-mail]>
Subject: [External] White Street Phase III permit renewal
Send 111mINVIRImIlls an _61.11MM to
Mr. Chao,
This email is a follow up response specifically to Item No. 2 in your October 11, 2019 email shown below. While
reviewing the City Council meeting minutes going back to January 2001, 1 was not able to find a formal motion to close
or reopen (which would infer that it had been closed) the White Street landfill.
1/6

Z.
In the July 17, 2001 City Council Meeting...
Councilmember Johnson moved the following: "It is the intent of this Council not to permit further any further
expansion of the White Street Landfill and to actively pursue alternative disposal options, using only the White Street
landfill to the capacity it is currently permitted as a bridge to other alternatives. In order to accomplish this intent, the
Council is instructing staff to further research and investigate the other three alternatives for disposal of municipal solid
waste which were outlined in the report prepared by HDR and any other alternatives, other than expansion of White
Street. Staff should be prepared to make a presentation on the merits of these other disposal options at a special
meeting of City Council to be held on September 11, 2001."
The motion was seconded by Councilmember Burroughs -White and adopted on the following roll call vote: Ayes:
Burroughs -White, Carmany, Holliday, Johnson, Jones, Perkins, Phillips, Vaughan and Vaughan. Noes: None.
The City's position has been to use the permitted capacity and not to expand Phase III. We are not requesting to expand
the landfill but rather use the capacity for the nearby waste water treatment plant sludge and ash residuals, special
projects as directed by Council, for emergency disposal should the transfer station go down and all other local disposal
options are exhausted and for future C&D disposal at the completion of Phase II. Our communication on this subject has
been consistent.
In a March 31,2011 letter from HDR to the NCDEQ (formerly NCDENR) on behalf of the City stated...
Currently the Phase III landfill is only receiving a small, select MSW waste stream from the City's wastewater treatment
plant as directed by the City Council. As such, random inspections are not being conducted because the waste is from a
known source and is homogeneous. Cover is only applied on days when waste is received. The balance of the MSW is
directed to the City's transfer station at this time, but could be redirected to the landfill should the Council vote to do so
or in case of an emergency. The City Council may also elect to dispose of C&D material in Phase III at the completion of
Phase II."
This position was confirmed in the May 3, 2011 City Council Meeting...
"Councilmember Wade spoke to due diligence; stated that a draft report had been done earlier by HDR; that the White
Street Landfill was never closed; had always remained the backup to be used as a secondary landfill; that it was
permitted; voiced concern with the use of wrong terminology; that discussions in 2001 were in small group meetings
where minutes were not recorded; and that she had researched the minutes from Council meetings."
This position was further confirmed during an August 16, 2011 in a City Council Meeting...
"Councilmember Wade made a motion that we direct the City Manager to begin contract negotiations with Gate City
Waste Services to conduct landfill operations on Phase III of the White Street Landfill; I further move that we restrict
the volume of waste to be received at the White Street Landfill to be City only waste; and that the City Clerk be
directed to advertise for a public hearing on the contract award to Gate City Waste Services. The motion was seconded
by Councilmember Rakestraw."
"Mayor Knight stated Council would vote on the main motion. The main motion was adopted on the following roll call
vote: Ayes: Knight, Rakestraw, Thompson, and Wade. Noes: Bellamy -Small, Kee and Perkins. Abstention: Matheny and
Vaughan."
In a February 5, 2015 letter from the City to NCDEQ (formerly NCDENR) and as part of our previous permit application...
"... we'll also provide verification of local government approval of our request. Our staff will work through our solid
waste Management Commission, City Council and City Attorney over the next 60 days to provide a letter from the City
Attorney outlining the conditions of use and acceptable materials of the White Street Phase III landfill (permit # 41-12)"
In a March 6, 2015 letter from the City to NCDEQ (formerly NCDENR)...
2/
5

"Phase III at the White Street landfill will continue to receive ash from the City's wastewater treatment plant. The
amount of ash received over the past 3 years has totaled less than 10,000 tons per year, and that quantity it is not
expected to increase over the permitted period."
"Phase 3 at the White Street landfill will serve as a backup facility for MSW in the event that the City's transfer station is
unable to be accessed and all other local disposal options (both public and private sector) have been exhausted. These
options include the Republic Services transfer station on Bishop Road, City of High Point landfill, Rockingham County
landfill, Forsyth County landfill, Randolph County landfill (operated by Waste Management, available late-2016)."
On March 27, 2015 A letter from the City of Greensboro attorney's office indicated ...
"Phase III at the White Street landfill will continue to receive ash from the City's wastewater treatment plant..."
and
"Phase III at the White Street landfill will serve as a backup facility for MSW in the event the City's transfer station is
unable to be accessed and all other local disposal options (both public and private sector) have been exhausted."...
The City's position on the use of Phase III has not changed since the original resolution and has been consistent through
two previous Phase III MSW permit renewals with NCDEQ. We can provide the meeting minutes if you request them.
We can also reproduce letters (previously submitted during the last two renewal requests) as documentation to the
City's position and status of the White Street landfill. I would request that NCDEQ proceed with their review of our
permit renewal application. Please respond if you feel otherwise and if you have any other questions please do not
hesitate to contact me at your convenience.
Richard P. Lovett
Environmental Compliance Support Manager
City of Greensboro
Field Operations Department
401 Patton Ave.
Greensboro, NC 27406
Phone - 336-373-4188
Fax - 336-373-2988
rich a rd. lovettQ-qreens boro-n c. gov
From: Lovett, Richard
Sent: Tuesday, October 22, 2019 2:58 PM
To: Chao, Ming-tai <min .chao ncdenr. ov>
Subject: FW: Determination of incompleteness of White Street Landfill 2019 Application for Continued Operation -
Permit No. 41-12, FID 1359414
Ming,
Please see my response in red below
Richard P. Lovett
Environmental Compliance Support Manager
City of Greensboro
Field Operations Department
401 Patton Ave.
Greensboro, NC 27406
A6

Z.
Phone - 336-373-4188
Fax - 336-373-2988
richard.lovett@,qreensboro-nc.gov
From: Chao, Ming-tai <[e-mail]>
Sent: Friday, October 11, 2019 1:53 PM
To: Lovett, Richard <Richard.Lovett@ereensboro-nc. oovv>
Cc: Stanley, Sherri <Sherri.Stanle ncdenr. ov>; Kirchner, Chuck <chuck.kirchner ncdenr. ov>; Ritter, Christine
<christine.ritter ncdenr. ov>; Plummer, Michael <Michael. PlummerP hdrinc.com>; Marriott, Chris
<Chris. M arriottPgreensboro-nc.gov>; Emil .Tucker hdrinc.com• Walker, Lewis <Lewis.Walker reensboro-nc. ov>
Subject: Determination of incompleteness of White Street Landfill 2019 Application for Continued Operation - Permit
No. 41-12, FID 1359414
CAUTION: This email originated from outside the organization. Do not click links or open attachments unless
you recognize the sender and know the content is safe. Report suspicious emails by clicking the "Phishing
Alert" button.
Dear Mr. Lovett:
Based on the September 10, 2019 Facility Compliance Inspection Report (Inspection Report) Items 26 and 36,
the White Street Landfill (Phase III), Permit No. 4112-MSWLF-1997, only receives wastewater treatment
sludge as solely waste for disposal at the landfill Cell 3 area. The Inspection Report is attaching to this e-mail
message. Pursuant to NCGS 130A-295.8(e), the Solid Waste Section hereby officially informs the City of
Greensboro that the received permit application titled as "Application for Continued Operation, City of
Greensboro, White Street Landfill — Phase III, Guilford County, Permit No. 41-12 (FID 1358029)" is an
incomplete permit application. This permit decision is made according the following facts:
The landfill has received (Inspection Report Items 26 and 36) and intentionally continue to receive the
wastewater treatment sludge as solely waste for disposal at the landfill cell. This waste disposal practice
violates Rule 15A NCAC 13B. 1626(1)(e) —
Wastewater treatment sludges may only be accepted for disposal in accordance with the following
conditions: (i) Utilized as a soil conditioner and incorporated into or applied onto the vegetative growth
layer but, in no case greater than six inches in depth; or (ii) Co -disposed if the facility meets all design
requirements contained within Rule .1624, and approved within the permit, or has been previously
approved as a permit condition. During the inspection, I unintentionally misspoke when describing
the waste being disposed of at the Phase III White Street landfill. The City received in FY 2018
for disposal in the Phase III landfill 6,129.32 tons of ash and 957.49 tons of sludge. This meets the
intent of (ii) above by co -disposing at a facility that complies with Rule .1624.
2. In 2001 the City Council determined not to pursue further expansion of the White Street Landfill (Phase
I1I), consisting of Cells 1, 2, & 3, and to actively pursue alternative waste disposal options, using only
the White Street Landfill to the capacity for which it is currently permitted as a bridge to other
alternatives. In 2006, the City constructs and operates a waste transfer station, Permit No. 4120T-
Transfer- in Burnt Poplar Road to transfer the collected permitted municipal solid wastes (MSW) at the
station and then dispose of at the permitted disposal facility in the State of North Carolina. As stated in
the Inspection Report Item 36, the White Street Landfill (Phase III) shall not receive any MSW except in
emergency. Item Number 36 indicated that the facility is permitted to receive solid waste from
Guilford County. Currently the facility is receiving sludge from the TZ Osborne WWTP (within
A
0

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Z.
Guilford County) and also (residential) MSW in emergency situations or specific City projects
(I.e. Nealtown Road Extension). These actions are consistent with historical activities approved by
NCDEQ (NCDENR) regulators in the past and have been consistent with NCDEQs (NCDENRs)
interpretation of the City Councils decisions related to the White Street Landfill.
Please be advised that a determination of completeness means that the application includes all required
components but does not mean that the required components provide all of the information that is required for
making a decision on the application by the Solid Waste Section.
The City shall submit the requested document that stated in the Inspection Report Items 44 and 45 and revise
the permit application document according to the "true and real" waste operations at the landfill. Until the
requested document is received by the Solid Waste Section, the permit reviewing processes is temporarily
terminated. Please submit the requested document in a timely manner and be aware of the response time frame
in NCGS 130A-295.8(e); failure to follow the requirements will result in a denial of the permit. If you have
question of the determination of incompleteness of the permit application, please contact myself. Have a
wonderful weekend.
��')yQ)
NDRTH CARDLINA J�\\\\\\EQi�"
OeparMenf of Fnvironmertal pual�
El
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Chao, Ming-tai
Sent: Friday, September 13, 2019 5:01 PM
To: Lovett, Richard <Richard.Lovett L= greensboro-nc.gov>
Cc: Stanley, Sherri <Sherri.Stanle ncdenr. ov>; Kirchner, Chuck <chuck.kirchner ncdenr. ov>; Ritter, Christine
<christine.ritter ncdenr.aov>; Plummer, Michael <Michael.Plummer hdrinc.com>; chris.marriottreensboro-nc. ov
Emil .Tucker hdrinc.com
Subject: White Street Landfill 2019 Application for Continued Operation - Permit No. 41-12
Dear Mr. Lovett:
/k

2.
The Solid Waste Section (SWS) received the life -of -site permit application for White Street MSWLF (Phase 3),
Permit No. 4112-MSWLF-1997; the document was uploaded to the Laserfiche with a FID 1358029. The SWS
will review the permit application shortly. Thank you for the submittal and have a wonderful weekend.
DE
NDRTH CARQ INA �
naparhnenl of Environmental Quality
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ip