4112_WhiteStreetMSWLF(Phase3)_Comment_LOSApp_FID1388043_20200204

##, 2020 Mr. Dale Wyrick, P.E. Director of Field Operations
City of Greensboro PO Box 3136 Greensboro, NC 27402-3136
Re: Comments on the Life-of-site Permit Application White Street MSWLF – Phase 3 Guilford County, Permit No. 4112-MSWLF-1997, File ID No. XXX Dear Mr. Wyrick:
The Solid Waste Section, Division of waste management completes a review of the life-of-site permit application (the Permit Application, FID 1358029) for a continued operating the White Street Municipal Solid Waste Landfill (MSWLF) unit – Phase 3, Permit No. 4112-MSWL-1997.
Below are the comments on the Permit Application.
1. In the December 6, 2019 letter (FID 1386797) the City Greensboro (City) stated that the
White Street MSWLF unit (Phase 3) will continue to receive wastewater treatment
sludge/incinerated ash (sludge/ash) from the City-owned TZ Osborne Water
Recalcination Facility (WRF) for final disposal and may utilize the landfill as a backup
disposal facility when the City’s Transfer Station (Permit No. 4120T-Transfer) is unable
to be accessed and all other local disposal options have been exhausted. To manifest the
purposed utilization of this landfill unit in the life-of-site Permit Application, a Facility
Plan should be prepared in which the landfill (Phase 3) chronological history of cell
development (gross capacity of the landfill unit and operating capacity and acreage for
each cell) and operation decision made by the local government should be provided.
Additionally, the Facility Plan shall
i. Append a document to show that the City Council agrees and authorizes the
utilization of the MSWLF unit (Phase 3) as the same manner as stated in the
December 6, 2019 letter (FID 1386797). The authorization documentation can be
in a form of a Resolution or meeting minutes. This requirement is reiterating the
request stated in the SWS response letter (FID 1386824) dated January 03, 2020.
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ii. Provide the descriptions of the landfill operation history according to the City
Council’s decision from 1997 to 2006, 2006 to present. The descriptions should
include, but not limited to:
a. Information of waste stream/type, in-place waste volume (cubic yard or
tonnage), surveyed elevations in the two stages: from 1997 to 2006, 2006 to
present.
b. A copy of meeting minutes or resolutions supporting for each milestone
decision made by the City Council.
iii. Detail the phased development and capacity for each cell development per Rule
15A NCAC 13B .0537.
iv. Provide Facility Plan Drawings per Rule 15A NCAC 13B .1619. The drawings
should include other permitted solid waste management units inside the White
Street Landfill Facility such as C&DLF unit, closed unlined MSWLF units, a
compost unit, etc. as stated in Section 5.3.3.2 of the Operation Plan.
The life-of-site Permit Application should also include the crucial documents approved previously which are requested in the comments below. Engineering Plan 2. According to Rule 15A NCAC 13B .1620(e), the Permit Application should provide the
Engineering Drawings including typical details as described in Section 3, such as the
constructed landfill base liner system and LCR piping layout & cleanout locations for
Cells 1, 2, & 3, leachate sumps or manholes (outside landfill boundaries as described in
Section 3.1.6.2), force-main alignment from sumps to leachate storage tanks, the leachate
discharge point to a sewer line.

3. (Sections 3.1.4 & 3.3) According to the latest Facility Compliance Inspection Report
regarding waste streams disposed at the landfill, it is apparent that the landfill upper
portion of Cells, 1, 2, & 3 becomes a landfill where is predominantly receiving
wastewater treatment sludge & ash for disposal since 2006 (as shown on Figure 5-2).
Therefore,
i. The final cover system and slope stability of the active working face of the
landfill must be properly designed according to the engineering properties (such
as moisture/degree of saturation, density, shear strength, permeability, etc.) of in-
place waste types or mixture (both co-disposal wastewater ash/sludge with
ordinary garbage prior to 2006 and predominant wastewater ash/sludge for
disposal since 2006), in-place waste volumes, geometry of waste placement (such
as alternate stratifications on Figure 5-2).
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ii. Additionally, the concerns of long-term slope stability at the interface between in-
placed MSW (Cells 1 & 2 - prior to 2006) and sludge/ash (Cell 3 - 2006 to
present) must be properly assessed.
iii. For a landfill predominantly received wastewater treatment sludge & ash for
disposal, the City must
a. Design and execute a waste solidification process(es) or standard operation
procedures (SOP) to demonstrate that sludge/ash alone or mixing with a
proposed bulk agent (s) will pertain a minimum shear strength (300 psf as
stated in Section 3.3), so that the landfill can stably and safely stand under
self-weight and an allowable external force as described in Section 3.3. The
above-mentioned process or SOP should include, but not limited to, the
routine field testing (including the sampling methods, testing method &
frequency of the in-placed waste shear strength, the training credential of the
sampling tech & soil laboratory, certification of test result by a NC
Professional Engineer), waste solidification procedures (including the
proposed bulk agent(s), equipment & location for mixing, mixed waste
spreading & compaction, etc.), procedures to manage failed section, and
record keeping.
b. Provide a plan to ensure the constructed LCR system won’t be clogged by the
disposed sludge/ash.
iv. Specify what kind geomembrane liner to be used as one of the components of the
proposed final cover system.
a. Provide the detailed calculations and design of the component of the final
cover system - drainage geocomposite material (DGM) (such as geonet)
overlain the geomembrane layer. The designed and specified GDM should
safely deliver/convey any percolation of stormwater through the protective
soil layer to downslope drainage system/feature without physically and
mechanically defect and biological clogging and to avoid any seepage flow or
excessive pore water pressure buildup inside the protective soil layer.
b. Anchor trench design for installing geosynthetic liner & DGM. The typical
details of the anchor trench should show on an Engineering Plan Drawing as
stated in Section 3.2.2.2 of the CQA Plan.

4. (Section 3.1.5) Please provide info of the LFGCCs at the landfill.
i. As-built drawings of the LFG collection system including the location s of piping
(lateral and header pipes) layout, gas wells, control valves, condensate
sumps/lockouts, & the blower/flare skid/station.
ii. As-built gas well scheme including X & Y coordinates and total depth of each gas
well.
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iii. The layout of piping carrying condensate/leachate from a knockout/sump to
manhole(s) leading to an on-site leachate tank or wastewater sewer lines.
iv. Append the copy of the current Title V air quality permit associated with the on-
site gas flare to the permit application.
v. According to Facility Compliance Inspection Report dated November 13, 2017,
the City planned to install a LFGTE system at the landfill facility. If the system is
completed and operational, please submit the copy of the Title V air quality
permit for the generator, and as-built system layout drawing.
vi. The Section should discuss the system decommissioning plan and all associated
costs should be included in the post-closure cost estimates.

5. (Section 3.1.6) Please provide the info of the leachate management at the landfill unit
according to Rule 15A NCAC 13B .1619(e)(4).
i. What are the maximum and operating capacities of each of the two leachate
storage tanks?
ii. What are the average monthly amounts of leachate? Provide chronological data
for the landfill unit since the date receiving waste for disposal. The data should
include surge volumes generated by extreme storm events – including extreme
storm events and hurricanes?
iii. Section 3.1.6.2 reports that “all leachate piping systems are equipped for periodic
flushing to remove any settled debris or other pipe restrictions.” Pursuant to
NCGS 130A-295.6(h)(3), please provide the copy of the record of leachate line
cleaning and remote camera inspection for the last five years.
iv. Describe if the contingency plan prepared and practiced for managing surge
volumes in Section 3.1.6.4 requires any modification based on the extreme storm
events occurred in recent years.

6. (Section 3.2) Because the landfill unit is not planning for any lateral expansion as
described in the September 13, 2019 cover letter, this Section should also describe the
landfill final cover system.
CQA Plan 7. This CQA Plan should also provide info of
i. The components of the proposed landfill final cover system including 18-inch-
thick compacted soil liner with a maximum permeability of 1*10-5 cm/sec,
geomembrane (LLDPE?), drainage geocomposite material, 18-inch-thick erosion
control layer, seeding scheme for the 6-inch-thick top soil layer, landfill gas
venting system, erosion control/storm water management, etc.
ii. The project specifications for each component of the landfill project as stated
throughout the CQA Plan.
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8. (Section 1.3.1.4) Contractor is also responsible for LCR system installation, constructing
final cover system, and landfill gas venting system.

9. (Section 2.2) The earthwork construction should include the preparation, backfilling and
grading the 18-inch-thick erosion control layer, one of the components of the proposed
final cover system.

10. (Section 2.3.1) This subsection should describe the QA/QC requirements of 12-in-thick
intermediate soil cover, considered as the subgrade of the compact soil liner or
geomembrane liner in the final cover system.

11. (Section 3.2.4.5.1) Please specify the ASTM testing methods, sample size, and shear
strain rate for seam strength and peel adhesion.

12. (Section 8.5) The survey items should also include the edges of all surface breaks (such
as toes, crests, ridges, & valleys), lab and field testing locations, patches/repair locations
of geosynthetic liners, locations of landfill gas wells/vents, piping runs/alignments
(including in-line sumps & valves).

13. (Section 8.9) Please add the following requirements to documentation:
i. The surveys should depict the information in topographic format and illustrate
actual data points.
ii. For thickness verification, the surveyor should format the tabulation results based
on the data of each point as follow:
a. Subgrade elevation.
b. Top elevation of the compacted soil liner.
c. Thickness of the compacted soil liner.
d. Top elevation of the soil erosion liner (for a final cover system) or the LCR
(for a baseliner system)
e. Final elevation of the final cover system or the baseliner system.
f. At a sloped area, the specified thickness of each layer is the measurement
perpendicular to the slope surface.
Operation Plan 14. Because the City will continue operating the special waste (predominant wastewater
treatment sludge/ash) disposal at the landfill but not routinely open the landfill for public
use for garbage/MSW disposal, the Operation Plan should be rewritten and state the facts
and include the following conditions/policies/law that must be routinely executed at the
landfill.
Mr. Wyrick ##, 2020 Page 6 of 10

i. The Facility Compliance Inspection Reports dated 2016 & 2017 stated that the
City did not conduct random waste screening on the sludge/ash generated from
the City’s WRF because the waste source is known and characterized.
a. Please provide the laboratory analytical testing results on sludge/ash since
2006 to present to confirm that the following prohibited wastes are excluded
from the waste stream for landfilling - hazardous wastes and hazardous waste
constituent as defined in NCGS 130A-290(a)(8) & (8a), polychlorinated
biphenyls (PCB) wastes as defined in 40 CFR 761 and dioxanes
(including1,4-dioxiane). A copy of the testing results shall be appended to the
Permit Application and shall be placed in the operating record at landfill
facility.
b. Because the DWM records don’t show that the SWS approved the City’s
request of waving or exempting from waste screening on sludge/ash from the
City WRF during that period time, the City must provide the copy of approval
document issued by the SWS.
ii. WWTP sludge/ash must free from liquid according to Rule 15A NCAC 13B
.1626(9)(c)(i) prior to accepting for disposal at the landfill. Please provide the
test results from 2006 to present in the Permit Application.
iii. The MSWLF unit is closed for public use except for the emergency proclaimed
by the City Council as stated in the Resolution which shall be appended to the
Permit Application. All permitted MSW shall be sent to City’s MSW Transfer
Station, Permit No. 4120T-Transfer at 6310 Burnt Poplar Road; C&D wastes
shall be disposed of at the City’s C&DLF, Permit No. 4103-CDLF-1998 at White
Street Landfill Facility. Please make a clear statement in the Operation Plan.
iv. The annual disposal rates (tons per year) for sludge and ash, respectively from
2006 to present should be summarized in the Operation Plan.

15. (Section 5.3.2)
i. Does landfill accept asbestos-containing material or waste for disposal when the
landfill opens for the public prior to 2006, during the period of Cone Boulevard-
Nealtown Road Connection construction project (removing wastes from an
inactive landfill unit) in 2016 and 2017, or in the future? If so, the requirements
per Rule 15A NCAC 13B .1626(1)(d) shall include in the Operation Plan.
ii. Remove and delete the prohibition of wastewater treatment sludge for disposal at
the landfill unit. The statement is contradicting the City’s or City council’s
decisions.

16. (Sections 5.4, 5.5 & 5.6)
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i. Will the progressive waste disposal practices of sludge/ash be different from the
those of ordinary MSW disposal? If the answer is yes, the modification should be
included.
ii. The SOP for solidify/spread/compact the solidified ash/sludge (ref Comment No.
3) should be discussed/described in these Sections.

17. (Section 5.6.1) Because the landfill has accepted and will continue predominately accept
wastewater treatment sludge/ash for disposal, the application of alternative daily cover
material (ADCM) at this landfill according to the NCGS 130A-295.6(h1) may be
approved only if the City can demonstrate that the requested SOP (ref Comment No. 4)
including such a ADCM. Please add this requirement to the section. Otherwise, please
state the landfill will not apply ADCM in operations.

18. (Section 5.8.3) The individual landfill gas monitoring plan for this landfill unit is
required. The Plan that shall include the requirements per Rule 15A NCAC 13B .1626(4)
and drawings to show the perimeter gas well locations can be prepared according to the
guidance document at the following web link
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Field%20Operations/Envir
onmental%20Monitoring/LandfillGasMonitoringGuidanceDocument.pdf.

19. (Section 5.12) The leachate management shall include
i. The requirements for routine inspection of leachate manhole(s), pump(s), storage
tanks per Rule 15A NCAC 13B. 1680(c). The inspection and maintenance/repair
activities must be documented and placed in the facility operating record.
ii. Storage facility closure requirements per Rule 15A NCAC 13B. 1680(f) and
associated costs shall be included in post-closure estimates.
iii. Prohibition of leachate recirculation. Because the landfill has accepted and will
continue predominately accept wastewater treatment sludge/ash for disposal, the
leachate recirculation operation at this landfill is prohibited due to significant
change of waste characteristic – high moisture content from the waste stream
accepted prior to 2006. Without any convincible results from a new pilot study,
the SWS rescinds the approval of operating leachate recirculation at this landfill.
iv. Descriptions of measures to manage, remediate, and control leachate outbreak at
landfill side slopes. Should seep occur, the responding plan must be prepared; the
plan in a minimum should include:
a. Reporting requirement per Rule 15A NCAC 13B .1604(b)(2)(L)(iii).
b. Submitting a sampling plan which can be prepared according to the guidance
document at the web link
https://edocs.deq.nc.gov/WasteManagement/0/edoc/1319075/MSW%20Leach
Mr. Wyrick ##, 2020 Page 8 of 10

ate_Release_Sampling_Guide.pdf?searchid=22b91c58-be48-4f48-97ec-
ae3766e88565

20. The attached Water Quality Monitoring Plan (WQMP) is out-of-date. The WQMP
should be prepared according to the guidance document in the link
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Field%20Operations/Envir
onmental%20Monitoring/SolidWasteSamplingGuidance.pdf. Additionally, the plan
should address the following concerns:
i. The constituent 1,4-Dioxane should be added to the surface and groundwater
detection monitoring program. This requirement and the reporting requirement of
“J” flag values stated in the SWS Memo dated 05/29/2018 shall be incorporated
into the revised WQMP.
ii. Regarding Alternate Source Demonstration (ASD) of select NC Appendix I inorganic constituents (antimony, cobalt, and vanadium) that have been detected above NC regulatory standards in groundwater underneath the landfill unit, please describe the lab results and conclusion made by the sampling events.
iii. Piezometers or wells that have been plugged and abandoned must be noted in the
monitoring drawings.

21. Please provide the rule-required landfill gas monitoring plan and drawings to show the
perimeter gas well locations. The gas plan should be prepared according the guidance in
the link
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Field%20Operations/Envir
onmental%20Monitoring/LandfillGasMonitoringGuidanceDocument.pdf.

Closure Plan
22. (Section 6.2) The QA/QC testing program for the proposed final cover system must be
provided in the CQA Plan and Technical Specification, a portion of the Permit
Application (Ref Comment Nos. 3 & 7). However, the City may modify the proposed
final cover system for an approval 90 days prior to closure or partial closure activities.

23. (Section 6.3) Please provide the referenced final contour drawings including
i. The typical details of the final cover system as described in Section 6.2.
ii. The details and layouts of stormwater and erosion control BMPs as described in
Sections 6.5 & 6.6.

Post-Closure Plan 24. (Sections 7.4) The Plan should discuss the road/path maintenance and repair so that the
accesses toward monitoring points, cap maintenance, and other described inspection
activities will not be obstructed. The inspection frequency should be added to the Section
7.5.
Mr. Wyrick ##, 2020 Page 9 of 10

25. (Section 7.4.3) The Post-Closure Plan should describe measures to manage, remediate,
and control leachate outbreak at landfill side slopes. Should seep occur, the responding
plan must be prepared; the plan in a minimum should include:
i. Reporting requirement per Rule 15A NCAC 13B .1604(b)(2)(L)(iii).
ii. Submitting a sampling plan which can be prepared according to the guidance
document at the web link
https://edocs.deq.nc.gov/WasteManagement/0/edoc/1319075/MSW%20Leachate
_Release_Sampling_Guide.pdf?searchid=22b91c58-be48-4f48-97ec-
ae3766e88565

26. (Section 7.4.4) Please discuss the maintenance and repair requirements for the on-site
sediment basins including the frequency of silt/sediment removal and the disposal
location.

27. (Section 7.4.5) The Plan should discuss the LFGCCs decommissioning plan including
leachate/condensate removal, and the related costs should be added to the cost estimates
for post-closure care activities.

28. (Section 7.5.1)
i. Please define the “benchmark” stated in the inspection list. The City should
conduct a routine inspection and necessary maintenance of waste edge markers to
ensure permanent physical markers can accurately identify the edge of the approved
waste footprint of the landfill unit.
ii. The inspection frequency of LFGCCs including the flare shall be consistent to the
permit condition (s) in the NC Air Quality Permit.

Cost Estimates 29. (Table 8-2) Please add the following cost items and associated costs to the post-closure
cost estimates.
i. Surface water sampling costs for 30 year (a semi-annual event).
ii. Leachate management costs including leachate disposal fee (as stated in Section
7.4.7), tank removal and sampling (as stated in Section 7.4.7), leachate line
flush/cleaning/inspection as required by NCGS 130A-295.6.
iii. LFGCCs O&M including condensate sump management and system
decommissioning costs. The costs may include converting a gas well to a passive
vent or removing or capping gas wells.

Mr. Wyrick ##, 2020 Page 10 of 10

If you have questions about the comments or request for further clarification, please contact me at
[phone] or by email at [e-mail]. Sincerely,
Ming-Tai Chao, P.E., Environmental Engineer Solid Waste Section Division of Waste Management (DWM)
cc: Ed Mussler, P.E., Section Chief Sherry C. Stanley, Permitting Branch Supervisor Christine Ritter, DWM Chuck Kirchner, DWM
Deb Aja, DWM File