34-02,012510ACMDemoApproveLTR

North Carolina Department of Environment and Natural Resources
Dexter Matthews, Director Division of Waste Management Beverly Eaves Perdue, Governor
Solid Waste Section Dee Freeman, Secretary
Winston-Salem Regional Office
January 25, 2010
Edward Gibson, P.E.
Solid Waste Engineer
City/County Utilities
325 Hanes Mill Road
Winston-Salem; NC 27105
Re: Alternative Cover Material Demonstration Authorization Letter
Hanes Mill Road MSW Landfill, Permit #34-02
Dear Mr. Gibson
This letter is in response to the request for approval to demonstrate the capability of using water treatment
plant sludge residuals as , an Alternative Cover Material (ACM) at the referenced landfill. This
Authorization Letter conditionally approves the Demonstration Project based on the request submitted to
this office by you on January 19, 2010 for a period of four (4) months. This period of time provides the
Operator with three (3) months or ninety (90) days of time to perform the Demonstration Project using the
approach outlined in your request as well as one (1) month to compile and submit the certified
Demonstration Report to the Solid Waste Section for review if requesting the permanent use of the ACM.
The approval expires on May 25, 2010.
The ACM must comply with 15A North Carolina Administrative Code (NCAC) 13B .1626(2)(b) which
requires the Operator to demonstrate that the ACM will control disease vectors, fires, odors, blowing litter,
and scavenging without presenting a threat to human health and the environment. The ACM shall not be
used more than five consecutive days without placing soil over the previously filled area.
The demonstration period does not allow for or give exemption to the requirements for Daily Cover. If the
use of the product is not sufficient for daily cover it should not be used. It is the responsibility of the
Operator to ensure adequate cover is being provided. The use of the product should be discontinued if it
does not appear to adequately cover the waste.
585 Waughtown Street, Winston-Salem, NC 27107
Phone: [phone] \ FAX: [phone] \ Internet: www.wastenotnc.org
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NorthCarolina
Naturally

ACM Demonstration Authorization Letter
Hanes Mill Road MSWLF, Permit #34-02
January 25, 2010, Pg 2
After three (3) months (90 days) of using the conditionally approved ACM, the Operator may then either:
(1) Provide a certified Demonstration Report demonstrating the feasibility to request approval
for the use of the ACM on a full-time basis, or
(2) Cease use of the ACM, properly dispose of any remaining ACM, and provide a Closure
Letter detailing the findings of the use of the material during the approval period and what
actions were taken to dispose of the material.
The certified Demonstration Project report must be signed by the Operator and certified by a professional
engineer licensed in North Carolina. The report should include documentation addressing the performance
and effectiveness of the material, the number of times the ACM was used, the quantities of the ACM, and
other supportive information, including photographs.
Following satisfactory demonstration of the ACM and the application, the Solid Waste Section may issue a
modified permit for the facility that includes the ACM operation:
Please note that the continuation of the use of this ACM is performance based. Should the application of
the ACM become impracticable or contribute to conditions hazardous to public health, safety or the
environment, the Operator is responsible for immediately terminating ACM use and applying compacted
earthen material cover in accordance with the Solid Waste Rules. Impracticable conditions are conditions
that make the placement of ACM difficult due to adverse climate such as rain, wind, frozen precipitation, or
other conditions that adversely affects the ability of the ACM to meet the Performance Standards. The
Operator must maintain a ready stockpile of earthen material cover and the equipment necessary to apply
the earthen material cover to respond to an adverse situation. Therefore, approval of the continued use of
the ACM may be revoked at any point in time by the Division.
A pre -operational meeting is required with the Section prior to starting this demonstration. If you
have any questions, please call me at 336-771-5095.
Sincerely,
�in Patron
Environmental Senior Specialist
Solid Waste Section
cc (via email):
Mark Poindexter, Field Operations Branch Head
Jason Watkins, Central District Supervisor
Donald Herndon, Compliance Officer
John Murray, Permit Engineer
Jan McHargue, Solid Waste Administrator — City/ County Utilities
Adam Rickett, Solid Waste Operations Specialist
David Bullins, Solid Waste Supervisor