9230_CAPLeachateManagement_20210205

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Civil & Environmental Consultants, Inc.
February 5, 2021
Ms. Davy Conners
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
North Carolina Department of Environmental Quality
Dear Davy:
Subject: Highway 55 C&D Landfill — Permit 92-30
Greenway Waste Solutions of Apex, LLC
Corrective Action Plans
CEC Project 111-370.0003
On behalf of Greenway Waste Solutions of Apex, LLC (GWS), Civil & Environmental Consultants, Inc.
(CEC) has prepared a Corrective Action Plan (CAP) to monitor and manage landfill leachate and a CAP
to monitor and manage organic leachate related to the compost facility. On January 5, 2021, GWS
received the Notice of Violation (NOV) (FID 1521993) from the North Carolina Department of
Environmental Quality Solid Waste Section (NCDEQ SWS). This NOV was received following a
facility inspection by NCDEQ SWS of the Greenway Waste Solutions of Apex C&D Landfill
(ACDLF), conducted on December 22, 2020 (FID 1521991), during which the NCDEQ SWS inspector
identified leachate releases from the landfill as well as composting areas at the facility.
During a January 25th, 2021 conference call with GWS, CEC, and NCDEQ, the NOV, schedule, NOV
response, and CAP requirements were discussed. A Sampling Plan will be submitted under separate
cover by GWS by February 5th, 2021. All parties agreed that the CAP for landfill leachate and organic
leachate would be prepared and submitted by February 5th, 2021 and include a summary of actions
taken to date by GWS personnel, as well as outline further actions, including (but not limited to)
operational changes such as daily inspections and personnel training.
As agreed during the January 25th, 2021 call, the attached CAP for both landfill leachate and organic
leachate were prepared to determine the underlying causes and immediate repairs needed, outline the
intermediate and operations changes required, and discuss the long-term strategy for managing the
leachate and organic leachate.
If you have any questions or comments, please feel free to contact me at [phone].
Sincerely,
CIVIL & ENVIRONMENTAL CONSULTANTS, INC.
� �' 6
Nathan Bivins, P.E. Scott L. Brown, P.E.
Project Manager Vice President
Attachments
cc: Mr. John Brown — Greenway Waste Solutions
3701 Arco Corporate Drive, Suite 400 1 Charlotte, NC 28273 1 p: 980-237-0373 f: 980-237-0372 1 www.cecinc.com

ATTACHMENTS
Civil & Environmental Consultants, Inc.

LEACHATE CORRECTIVE ACTION PLAN
FOR
GREENWAY WASTE SOLUTIONS OF APEX, LLC
CONSTRUCTION AND DEMOLITION DEBRIS LANDFILL AND LARGE
TYPE 1 SOLID WASTE COMPOST AND REPROCESSING FACILITY
NO.92--30-CDLF
5940 OLD SMITHFIELD ROAD
APEX, NC 27539
WAKE COUNTY, NORTH CAROLINA
Prepared For:
GREENWAY WASTE SOLUTIONS OF APEX, LLC
APEX, NC
Prepared By:
CIVIL & ENVIRONMENTAL CONSULTANTS, INC.
CHARLOTTE, NC
CEC PROJECT NO. 111-370.0003
North Carolina Board of Examiners
For
Engineers and Surveyors
License No. C-3035
FEBRUARY 5, 2021
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Nathan Bivins, P.E.
Project Manager
Scott Brown, P.E,
Vice President
Civil & Environmental Consultants, Inc.
Charlotte 3701 Arco Corporate Drive, Suite 400 1 Charrotte, NC 28273 1 p: 980-237-0373 f:980-237-0372 1 www.cecinc.coln

TABLE OF CONTENTS
4.0 INTRODUCTION..............................................................................................................1
2.0 SITE BACKGROUND......................................................................................................2
2.1 SITE DESCRIPTION............................................................................................. 2
2.2 LEACHATE SEEPS AND RELEASES................................................................ 3
2.3 UNDERLYING CAUSES...................................................................................... 3
2A REPAIRS AND IMMEDIATE ACTION.............................................................. 4
2.5 OPERATIONAL AND INTERMEDIATE CONTROLS ...................................... 5
3.0 LONG-TERM CONTROLS.............................................................................................7
4.0 EVALUATION OF EFFECTIVENESS..........................................................................8
Civil & Environmental Consultants, Inc. -i- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

1.0 INTRODUCTION
Civil & Environmental Consultants, Inc. (CEC) respectfully submits this Corrective Action Plan
(CAP) on behalf of Greenway Waste Solutions of Apex, LLC (GWSA) for the Apex C&D Landfill
(ACDLF). This Corrective Action Plan is prepared to bring the Facility into compliance with the
requirements of the regulations in 15A NCAC 13B .0542 (1)(4) and 15A NCAC 13B .1406 (4).
This CAP addresses the underlying causes of the leachate seeps and potential releases at the
Facility, the repairs and measures needed to satisfy the requirements of the regulations, and the
long-term approach to control leachate.
Civil & Environmental Consultants, Inc.
-1- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

2.0 SITE BACKGROUND
2,1 SITE DESCRIPTION
The Facility is located in Apex, Wake County, North Carolina, off of NC Highway 55. The
Facility is bordered by Highway 55, Highway 540, and Old Smithfield Road. The immediate
surrounding area is rural and primarily wooded. There is residential development to the south and
east in the vicinity of the property. The landfill is classified as a C&D Landfill under Permit
Number 92-30. The Facility is currently permitted for three operating phases (Phases I, II, III)
totaling 37.2 acres.
Phase I is approximately 17.8 acres in size. Phase II is approximately 14.8 acres in size. Phase III
is approximately 4.6 acres and the total landfill size is 37.2 acres. Internal roads are maintained to
be passable by disposal vehicles in all weather for access to the operations areas. Access roads are
provided to reach monitoring wells and other locations requiring periodic servicing.
The Landfill facility has an entrance (Old Smithfield Road) off of Highway 55 in the eastern
portion of the site. A scalehouse, scales, parking stalls, and a gate are located in the entrance
corridor. A total of six (6) sediment basins are placed in strategic locations around the landfill to
prevent sediment from being transported off -site.
The currently Permitted Capacity and Acreages of each of the phases are shown in the chart below:
Area
Gross Capacity yd3
Currently Permitted
Acreage
Phase I
1,411,626
17.8
Phase II
1,470,070
14.8
Phase III
242,940
4.6
Totals
3,124,636
37.2
Civil & Environmental Consultants, Inc.
-2- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

2.2 LEACHATE SEEPS AND RELEASES
During a facility inspection by the North Carolina Department of Environmental Quality
(NCDEQ) Solid Waste Section (SWS) of the ACDLF, conducted on December 22, 2020 (FID
1521991), the NCDEQ SWS inspector identified leachate releases from the landfill. Four
identified leachate releases from the landfill area constitute a violation of 15A NCAC 13B .0542
(1)(4)A. A description of each violation and respective initial response measures are discussed
below.
2.3 UNDERLYING CAUSES
Leachate is the resultant liquid created when rainfall percolates into the landfill waste mass and
then slowly drains through the waste under gravity. Leachate is not collected at the landfill; thus,
leachate generated at the facility and runoff from the facility must be managed in such a manner
that ground and surface water quality will not be adversely affected. The facility must be
maintained to prevent the accumulation of stormwater and leachate on composting areas, storage
areas, and roads. All operational and storage areas with temporary or intermediate cover should be
sloped to drain surface water away from the operational area to stormwater features to prevent
standing water, ponding, and infiltration of surface water into the waste mass. Water that comes
in contact with solid waste shall be contained on -site or properly treated prior to discharge.
Leachate seeps occur because there are preferential pathways inside the waste mass for leachate
to travel along. Surface water percolates through the waste mass and then the leachate hits these
preferential pathways until it seeps out at the sideslope or at the toe of slope of the landfill. Seeps
may lead to leachate releases if not recognized and repaired in a timely fashion.
Leachate seeps may be contained within the landfill by improving the soil type, area, and thickness
in specific areas that have leachate seep issues.
Civil & Environmental Consultants, Inc.
-3- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

Leachate seeps and releases may also be prevented by increasing runoff and decreasing infiltration,
thus decreasing the overall leachate quantity in the landfill. Measures to address the long-term
leachate generation rate are discussed in Section 3.0.
2.4 REPAIRS AND IMMEDIATE ACTION
Leachate Release 1
Leachate Release 1 is located on the north central slope of the landfill, near the border of the closed
Phase I disposal area and the inactive Phase II disposal area. This release is a broad seep which
was observed flowing into Basin 4.
GWSA personnel installed a berm along the base of the slope below the Leachate Release l area
in order to contain leachate within the landfill footprint area.
Leachate Release 2
Leachate Release 2 is located on the western slope of the closed Phase I disposal area. Leachate
in this area was observed flowing across the access road into Basin 1.
GWSA personnel installed a containment berm below Leachate Release 2 for the purpose of
containing leachate within the landfill footprint area. On January 5, 2021, GWSA over -excavated
the leachate release area and installed a compacted soil plug. GWSA personnel over -excavated
and plugged this release area again on January 13, 2021 following the observation of leachate
flowing from the perimeter of the soil plug. Due to the consistent flow of leachate from this
release, berm material is currently being excavated and replaced on a regular basis as needed.
Excavated berm material is being placed in the active Phase 3 disposal area.
Leachate Release 3
Leachate Release 3 is located on the southern slope of the inactive Phase II disposal area. Leachate
from this release was observed following a stormwater swale into Basin 3.
Civil & Environmental Consultants, Inc.
-4- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

GWSA personnel over -excavated the leachate release area and installed a compacted soil plug to
inhibit leachate flow from this release area. Excavated material from this leachate release area
was placed in the active Phase 3 disposal area.
Leachate Release 4
Leachate Release 4 is located approximately 200 feet east of Leachate Release 3 along the southern
slope of the inactive Phase II disposal area. Leachate from this release was observed following a
stormwater swale into Basin 3.
GWSA personnel over -excavated the leachate release area and installed a compacted soil plug to
inhibit leachate flow from this release area. Excavated material from this leachate release area
was placed in the active Phase 3 disposal area.
2.5 OPERATIONAL AND INTERMEDIATE CONTROLS
GWSA personnel will implement several operational controls to control leachate seeps and
releases in the intermediate future until a more permanent solution is achieved.
GWSA personnel will undergo training in the following areas to help facilitate these operational
goals:
- Monitoring grading and maintaining positive drainage in operational and storage areas to
maintain surface water discharge and prevent ponding.
- Monitoring the sideslope, toe of slope, and perimeter stormwater ditches for leachate seeps
to identify seeps before they become releases. Staff will be trained to monitor operational
areas for discolored soils, stained vegetation, odors, sheens or streaks in surface water, and
other leachate indicators.
This training will be conducted within 30 days of submittal of this plan.
• GWSA personnel will increase the inspection frequency of the ACDLF from "regularly"
to weekly, at a minimum, in addition to after each major rainfall event. A log of the landfill
Civil & Environmental Consultants, Inc. -5- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

inspections will be maintained in the scalehouse. If seeps are identified during an
inspection, repair and remediation efforts will be commence to prevent that seep from
becoming a leachate release. Repairs and remediation may involve over -excavation and
compacted soil placement, increased cover soil thickness, and berm construction. If a
leachate release is observed, ACDLF will Notify the Solid Waste Section (SWS) within 24
hours of any release or discharge outside of landfill unit per Rule 15A NCAC 13B
.1604(b)(2)(L)(iii).
Civil & Environmental Consultants, Inc. -6- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

3.0 LONG-TERM CONTROLS
The operational and intermediate controls will be implemented until the following long-term
solutions can be evaluated and, if deemed an effective solution, implemented. These long-term
control options must be evaluated based on a number of factors, including the corrective action
sampling, data collected from the site, operational control measures efficacy, expected lifespan of
the active landfill, and other factors. Possible long-term controls may include:
- Temporary impermeable barriers to prevent surface water infiltration;
- Leachate collection measures like collection trenches;
- Extraction wells or other active dewatering measures to reduce the amount of leachate in
the waste mass; and
- Closure.
Ultimately closure of the site will prevent significant surface water infiltration and leachate
generation, which will in turn prevent leachate seepage and releases.
Civil & Environmental Consultants. Inc. -%- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

4.0 EVALUATION OF EFFECTIVENESS
GWSA personnel have implemented the repairs and immediate action discussed in Section 2.4 and
will begin the operational and intermediate control measures discussed in Section 2.5. Operational
and Intermediate controls will be evaluated and may be modified based on the leachate seep area
outcomes and based on the daily inspection logs. If leachate seeps cannot be managed by the
measures discussed in this CAP, the CAP will be revised and resubmitted to DEQ.
Civil & Environmental Consultants. Inc. -8- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

ORGANIC LEACHATE CORRECTIVE ACTION PLAN
FOR
GREENWAY WASTE SOLUTIONS OF APEX, LLC
CONSTRUCTION AND DEMOLITION DEBRIS LANDFILL AND LARGE
TYPE 1 SOLID WASTE COMPOST AND REPROCESSING FACILITY
NO.92-30-CDLF
5940 OLD SMITHFIELD ROAD
APEX, NC 27539
WAKE COUNTY, NORTH CAROLINA
Prepared For:
GREENWAY WASTE SOLUTIONS OF APEX, LLC
APEX, NC
Prepared By:
CIVIL & ENVIRONMENTAL CONSULTANTS, INC.
CHARLOTTE, NC
CEC PROJECT NO.111-370.0003
North Carolina Board of Examiners
For
Engineers and Surveyors
License No. C-3035
FEBRUARY 5, 2021
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Nathan Bivins, P.E.
Project Manager
Scott L. Brown, PR
Vice President
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Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive, Suite 400 1 Charlotte, NC 28273 1 p: 980-237-0373 f: 980-237-0372 1 www.cecinc.coni

TABLE OF CONTENTS
4.0 INTRODUCTION..............................................................................................................1
2.0 SITE BACKGROUND......................................................................................................2
2.1 SITE DESCRIPTION............................................................................................. 2
2.2 LEACHATE SEEPS AND RELEASES................................................................ 2
2.3 UNDERLYING CAUSES...................................................................................... 2
2A REPAIRS AND IMMEDIATE ACTION.............................................................. 3
2.5 OPERATIONAL AND INTERMEDIATE CONTROLS ...................................... 4
3.0 CONTINGENCY PLAN...................................................................................................6
4.0 EVALUATION OF EFFECTIVENESS..........................................................................7
Civil & Environmental Consultants, Inc. -i- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

1.0 INTRODUCTION
Civil & Environmental Consultants, Inc. (CEC) respectfully submits this Corrective Action Plan
(CAP) on behalf of Greenway Waste Solutions of Apex, LLC (GWSA) for the Apex Construction
and Demolition Landfill (ACDLF). This Corrective Action Plan is prepared to bring the Facility
into compliance with the requirements of the regulations in 15A NCAC 13B .0542 (1)(4) and 15A
NCAC 13B .1406 (4). This CAP addresses the underlying causes of the organic leachate seeps
and potential releases at the Facility, the repairs and measures needed to satisfy the requirements
of the regulations, and the long-term approach to control organic leachate.
Civil & Environmental Consultants, Inc.
-1- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

2.0 SITE BACKGROUND
2.1 SITE DESCRIPTION
The Facility is located in Apex, Wake County, North Carolina, off NC Highway 55. The Facility
is bordered by Highway 55, Highway 540, and by Old Smithfield Road. The immediate
surrounding area is rural and primarily wooded. There is residential development to the south and
east in the vicinity of the property. The landfill also includes the Type 1 Large Composting and
Processing facility under Permit Number 92-30. The Facility is currently permitted for three
operating phases (Phases I, II, III) in the Current C&D Landfill totaling 37.2 acres and for the large
Type 1 composting and reprocessing facility.
The facility has an entrance (Old Smithfield Road) off Highway 55 in the eastern portion of the
site. A scalehouse, scales, parking stalls, and a gate are located in the entrance corridor. A total of
six sediment basins are placed in strategic locations around the facility to prevent sediment from
being transported off -site.
2.2 LEACHATE SEEPS AND RELEASES
During a facility inspection by the North Carolina Department of Environmental Quality
(NCDEQ) Solid Waste Section (SWS) of the ACDLF, conducted on December 22, 2020 (FID
1521991), the NCDEQ SWS inspector identified leachate releases from the composting areas at
the facility. Two organic leachate releases were identified from composting areas, which
constitute a violation of 15A NCAC 13B .1406 (4). A description of each violation and respective
initial response measures are discussed below.
2.3 UNDERLYING CAUSES
Organic Leachate is the resultant liquid created when rainfall percolates into the compost
windrows and then slowly drains through the compost under gravity. Leachate is not collected at
the facility; thus, leachate generated at and runoff from the compost must be managed in such a
Civil & Environmental Consultants, Inc. -2- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

manner that ground and surface water quality will not be adversely affected. The facility must be
maintained to prevent the accumulation of stormwater and leachate on composting areas, storage
areas, and roads. All operational and storage areas should be sloped to drain surface water away
from the operational area to stormwater features to prevent standing water, ponding, and
infiltration of surface water into the waste mass. Water that comes in contact with compost shall
be contained on -site or properly treated prior to discharge. Leachate seeps may lead to leachate
releases if not recognized and repaired in a timely fashion.
2.4 REPAIRS AND IMMEDIATE ACTION
Organic Leachate Release 1
Organic Leachate Release 1 is located in the Northwest Compost/Wood Processing Area.
Leachate from the north and south side of the compost windrows in this area was observed flowing
east into a stormwater swale, which conveyed leachate into Basin 5. Observed discoloration of
standing water within Basin 5 was noted in the NOV. Leachate was also observed downgradient
of the Basin 5 outfall.
GWSA personnel excavated drainage swales around the compost windrows in order to improve
drainage from the windrow area. GWSA also installed AMC Floc Blocks as well as Filtrexx
EnviroSoxx Bactoloxx and Metraloxx waddles within the drainage swale immediately upgradient
of Basin 5 for the purpose of treating future runoff from the compost windrow area. GWSA intends
to treat water contained in Basin 5 by pumping and recirculating water through these Floc Blocks
and Filtrexx EnviroSoxx.
Organic Leachate Release 2
Organic Leachate Release 2 is located in the East Compost Area. Leachate from compost
windrows was observed in a stormwater swale on the southern side of the composting area, which
continued to follow the swale into temporary Basin 6A.
GWSA personnel excavated existing drainage swales around the compost windrows in order to
improve drainage from the compost area. GWSA also installed AMC Floc Blocks as well as
Civil & Environmental Consultants, Inc. -3- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

Filtrexx EnviroSoxx Bactoloxx and Metraloxx waddles within the drainage swale immediately
upgradient of Basin 6A for the purpose of treating future runoff from the compost windrow area.
2.5 OPERATIONAL AND INTERMEDIATE CONTROLS
GWSA personnel will implement several operational controls to control organic leachate seeps
and releases in the intermediate future until a more permanent solution is achieved.
Training
GWSA personnel will undergo training in the following areas to help facilitate these operational
goals:
- Monitoring grading and maintaining positive drainage in operational and storage areas to
maintain surface water discharge and prevent ponding; and
- Monitoring the compost processing and storage for leachate seeps to identify seeps before
they become releases. Staff will be trained to monitor operational areas for discolored
soils, stained vegetation, odors, sheens or streaks in surface water, and other leachate
indicators.
This training will be conducted within 30 days of submittal of this plan.
Inspections
GWSA personnel will increase the inspection frequency of the ACDLF from "regularly" to
weekly, at a minimum, in addition to after each major rainfall event. A log of the landfill
inspections will be maintained in the scalehouse. If seeps are identified during an inspection,
repair and remediation efforts will be commence to prevent that seep from becoming a leachate
release. Repairs and remediation may involve regrading windrows, rearranging the processing
configuration, constructing containment berms, and removing contaminated soil. Other possible
operational solutions to prevent organic leachate seeps are identifying other potential storage areas
for windrow storage, which would entail permitting those areas prior to compost placement.
Civil & Environmental Consultants, Inc.
-4- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

If a leachate release is observed, ACDLF will Notify the Solid Waste Section (SWS) within 24
hours of any release or discharge outside of landfill unit per Rule 15A NCAC 13B
1604(b)(2)(L)(iii).
Operational Changes
The current operational compost areas in the northwest and east compost areas will be
reconfigured. The area will be regrading and reorganized such that the compost windrows are
placed on compacted soil, in windrows with a maximum height of six feet and width of fifteen
feet. Appropriate fire lanes will be re-established and the areas will be regraded to ensure adequate
drainage and prevent ponding. The Northwest storage area will be confined to mulch storage only
until a revised compost plan has been submitted to NCDEQ and is approved. These operational
changes have begun but may take some time to complete, since excess product was stored on -site
during 2020 based on product user changes and the effects of the COVID-19 pandemic. GWSA
staff will keep NCDEQ updated on the improvement of these operational changes as they progress.
Civil & Environmental Consultants, Inc. -5- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

3.0 CONTINGENCY PLAN
Should an instance of on -site equipment failure or temporary shutdown of the facility occur, all
incoming loads of material shall be stockpiled at the drop-off area. If the operational and
intermediate measures are not effective, or if there is a change in sources or end user of the compost
material in the future, the Facility will attempt to find alternate methods of removing the processed
material off -site in order to prevent excess storage of product. These may include finding
additional long-term options for the product, providing rental equipment for processing, and
identifying alternate areas off -site for storage and/or placement. ACDLF will notify NCDEQ of
any operational changes in processing configuration or product disposal.
Civil & Environmental Consultants. Inc. -6- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021

4.0 EVALUATION OF EFFECTIVENESS
GWSA personnel have implemented the repairs and immediate action discussed in Section 2.4 and
will begin the operational and intermediate control measures discussed in Section 2.5. Operational
and Intermediate controls will be evaluated and may be modified based on the organic leachate
seep area outcomes and based on the daily inspection logs. If organic leachate seeps cannot be
managed by the measures discussed in this CAP, the CAP will be revised and resubmitted to
NCDEQ.
Civil & Environmental Consultants. Inc. -%- Corrective Action Plan
Greenway Waste Solutions of Apex, LLC
February 2021