0107_KeyPropertyLCIDLF_Comments_OP_FID1404927_20200430

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Chao, Ming-tai
To:chad huffine
Cc:Stanley, Sherri; Kirchner, Chuck
Subject:Comments on the revised Operations Plan, Key Property LCIDLF, 01-07, FID
Hi Chad:

After completing a review of the revised Operations Plan (FID 1404925) received on April 27, 2020, the Solid
Waste Section (SWS) has several comments below:

1. (Preface)
i. The name of the NCDENR is incorrect. The correct name is North Carolina Department of
Environmental Quality (NCDEQ). Throughout the entire document please use the correct name
of the NCDEQ.

ii. The NCDEQ Winston-Salem Regional Office address is 450 West Hanes Mill Road, Suite 300,
Winston-Salem, NC 27105.

2. The Solid Waste Section shall only follow the definitions contained in NCGS 130A-290 and 40 CFR
260.10 including subsequent amendments and editions to regulate the waste management facility or unit
in the State of North Carolina. The definitions in the section of “Landfill Definitions and Terminology”
can not overrule the state and federal laws.

3. (Operations Plan)
i. Please be more specific the acceptable waste stream:
a. Concrete includes non-aqueous, solid concrete products or blocks). Flowable concrete/fill is
prohibited for disposal.
b. Post-consumer asphalt shingle is not acceptable at this facility.
c. Soil or earthen material shall be an un-contamination earthen material and meet the
“unrestricted use standards" - meaning contaminant concentrations for each environmental
medium that are acceptable for all uses per NCGS 130A-310.65. Soil or earthen material
shall have any contaminant with a concentration less than or equal to that in the NC
Residential Health Base Preliminary Soil Remediation Goal (NC PSRG) which can be found
in the web link:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SF/RiskBasedRemediation/updates-
december-2019/1.-2019-Dec-PSRG-Table.pdf. Please add the requirements to the
Operations Plan. The copy of NC PSRG (Residential Health Base) must be appended to the
Operations Plan.

ii. Forsythe is a typo.

iii. The facility is a permitted waste management facility; therefore, delete the phrase “if permitted.”

4. (General Operations)
i. Please use inert debris strictly limited to concrete, brick, concrete block, uncontaminated soil,
rock, and gravel which are generated from land clearing activities. “Inert construction debris” is
generated from construction activities which is not permitted for a disposal in a LCIDLF.
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ii. Provide Site Plan Drawing to show all designated locations/areas of the LCIDLF & non-disposal
units such as inert debris and wood waste treatment and process units, entrance/gate, haul roads,
Sandy Cross Road, and adjacent drainage features/water bodies.

iii. The facility is collecting wood, leaf debris, and grass clippings, yard trash for composting (as
described in the Final Design Information and Documents); therefore, the operations plan for a
Type 1 compost unit/facility (either Large or Small as defined in Rule 15A NCAC 13B .1402,
depending on the operational extent and volume) is required and shall be prepared according
Section Rule .1401 through 1410. The link of the rules can be found
http://reports.oah.state.nc.us/ncac.asp?folderName=/Title%2015A%20-
%20Environmental%20Quality/Chapter%2013%20-%20Solid%20Waste%20Management.
Please be advised that the Large Type-1 facility is proposing, a separate permit, if the permit
application is approved, will be issued to the compost facility with a unique permit number and a
10-year permit cycle.

iv. According to Google Map, the yard/wood wastes are likely stockpiling the inactive area [existing
Landfill Area #1 (19.7 acres) & #2 (1.99 acres)] of the LCIDLF which is violating the Rule 15A
NCAC 13B .1404(a)(10). The material must either be removed to new locations or add the rule-
required pad.

v. Provide following info of each unit: dimensions (extents) and maximum volume of each type
waste/processed material (a total of both recyclable wastes and the processed material/products).

vi. Incorporate the rule-requirements for all recyclable and recover material [per NCGS 130A-
309.05(c)] to this Section:
In order to qualify as a recovered material, the material shall be managed as a valuable
commodity in a manner consistent with the desired use or end use, and all of the following
conditions shall be met:
(1) Seventy-five percent (75%), by weight or volume, of the recovered material stored at a
facility at the beginning of a calendar year commencing January 1, shall be removed from
the facility through sale, use, or reuse by December 31 of the same year.
(2) The recovered material or the products or by-products of operations that process recovered
material shall not be discharged, deposited, injected, dumped, spilled, leaked, or placed
into or upon any land or water so that the products or by-products or any constituent
thereof may enter other lands or be emitted into the air or discharged into any waters
including groundwaters, or otherwise enter the environment or pose a threat to public
health and safety. Facilities that process recovered material shall be operated in a manner
to ensure compliance with this subdivision.
(3) The recovered material shall not be a hazardous waste or have been recovered from a
hazardous waste.
(4) The recovered material shall not contain significant concentrations of foreign constituents
that render it unserviceable or inadequate for sale, or its intended use or reuse.

vii. For operating a yard or wood waste collection facility, the Operations Plan should describe
a. The maximum dimensions of each stockpile/windrow – width & length (for a windrow) or
base diameter (for a stockpile) and height.
b. The minimum isle distance between each stockpile/windrow which shall be 25 feet [Per Rule
15A NCAC 1404(a)(8)] or the one approved by the local fire marshal.
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viii. Operations involving waste treatment and process (T&P) such as grinding and sorting of
recyclable/ recovered material at units described in this Section shall be regulated by Rule 15A
NCAC 13B .0302. The minimum 50-feet buffer from any drainage features must be identified
on the Site Plan drawing and maintained. http://reports.oah.state.nc.us/ncac/title%2015a%20-
%20environmental%20quality/chapter%2013%20-
%20solid%20waste%20management/subchapter%20b/15a%20ncac%2013b%20.0302.pdf.
Please address the counter measures to prevent and/or mitigate potential nuisances such as odor,
windblow trash, dust, leachate.

5. Throughout the application, erosion and sediment controls are mentioned but the rule-required erosion
and sediment control permit can not be located in the SWS records. Please provide the copy of the
approved erosion and sediment control plan and permit (either issued by the County or the NC Land
Quality Section) associated the landfill and other non-disposal waste management units.

6. (Inspection and Maintenance)
i. Edge markers identified the landfill waste boundary should be established by using durable
material which is required and constantly maintained; the edge markers should be included in the
inspection and maintenance lists.
ii. The BMPs for erosion and sediment control at the facility should be included in the inspection
and maintenance lists. The routine and non-routine inspection shall be conducted according to
the Erosion and Sediment Control Permit.
iii. The leachate outbreak at the landfill sloped areas should be included in the inspection and
maintenance lists.

7. (Final Design Information and Documents)
i. The facility permit (DIN 28369) dated August 10, 2017 approved the landfill disposal waste
footprint of 15.08 acres at the new expansion area of 29.07-acre landfill property (on the west
side of the Boyds Creek Tributary 2). The section describes the disposal extent of the LCIDLF is
13.09 acres. Please double check the acreage of the landfill. If the revised 13.09-acre waste
footprint is confirmed, please revise the landfill fill grade plan (layout and cross sections) and the
landfill gross capacity accordingly.
ii. The SWS does not previously receive any approved documents or letters described in this section
including those stated in Rule 15A NCAC 13B .0564 (2), (3), (4), & (5). Please provide a copy
of each approval.
iii. The 100-year flood map for the region encompasses the facility has been redone in 2017. Please
re-examine the flood impact area on the map to confirm the new expansion area of the LCIDLF
is outside the 100-year flood zone [per Rule 15A NCAC 13B .0564(1)].

8. (Contingency)
i. Fire report and record are required. Should a fire or explosion occur, the operator shall verbal
notice to the SWS (at 336-776-9633, 919-707-8200, or 877-623-6748) within 24 hours and
written notification within 15 days. Written notification must include the suspected cause of fire
or explosion, the response taken to manage the incident, and the action(s) to be taken to prevent
the future occurrence of fire or explosion. The standard fire report form can be downloaded from
the following web link:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf.
Please append the report form to the Operations Plan.
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ii. Add the DEQ Winston-Salem Regional Office phone number 336-776-9800 And NCDEQ
Emergency Response phone numbers [phone] or [phone] to the contact list. 
Please contact me if you have any questions of the aforementioned comments.

Regards,

From: chad huffine <[e-mail]>  
Sent: Monday, April 27, 2020 4:12 PM 
To: Chao, Ming‐tai <[e-mail]> 
Subject: [External] Re: Shingles vs. Asphalt. 

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

Ming:  
Please review the attached word document. 
Is this sufficient for the work we need to update the landfill work required? 
Updates are in green print. 
Thank you, 
Chad 

On Wed, Apr 15, 2020 at 11:22 AM chad huffine <[e-mail]> wrote: 
Good Morning Ming  

If a landfill can accept asphalt pavement, can it also accept roofing shingles? 
Thank you, 
Chad