34-02_HanesMillRdMSWLF_Comment_DIN26330_20160629

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director
Solid Waste Section

June 29, 2016

Ms. Jan McHargue, PE
Solid Waste Administrator
City/County Utilities
P.O. Box 2511
Winston-Salem, NC 27102

Re: Comment on the Permit Amendment Application
Hanes Mill Road Municipal Solid Waste Landfill (MSWLF)
Forsyth County, North Carolina
Permit No.3402-MSWLF-1997, Document ID No. (DIN) 26330

Dear Ms. McHargue:

On June 06, 2016, the Division of Waste Management (DWM), Solid Waste Section (the SWS)
received the permit amendment application for requesting an approval to continue operating the
lined Hanes Mill Road Municipal Solid Waste Landfill (MSWLF) - Phase 1 (Cells 1, 2, & 3) and
Phase 2 (Cell 4). The permit amendment application (DIN 26171) is prepared by HDR
Engineering, Inc. of the Carolinas (HDR) on behalf of the Winston-Salem/Forsyth County
City/County Utility Commission (the Commission).

The SWS completes a review of the engineering portions of the permit amendment application
and has several comments stated below. The SWS Hydrogeologist is conducting a review of the
environmental media monitoring plans. Upon completing the review, he or she may issue the
Commission a separate comment letter to request clarifications on some issues or additional
information, if needed.

General
1. Throughout the permit application document please use the correct title of the Division of
Waste Management, not the Division of Solid Waste Management.

2. According to Rule 15A NCAC 13B .1619(b)(1), the permit amendment application
(either the Facility Plan or the Operations Plan) should provide descriptions and operation
requirements for non-disposal waste management units including the residential drop area
and two recycle units – white goods/scrap mental unit, scarp/used tire collection area,
which are operating inside the landfill facility. Please describe each unit structure
features, the operation procedures [such as waste screening; sign posted for waste
collection; maximum capacity at any time; contact info of the off-site waste
Ms. Jan McHargue, PE
June 29, 2016
DIN 26330
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treatment/process facility; waste hauler(s) and permit number, if applicable; Freon
removal (applicable to white goods only) procedures and responsibility; non-
conformance wastes removal and disposal, etc.].

Facility Plan
3. Please provide the info in the Facility Plan which will be incorporated into the new
Permit to Operate:
i. The in-place waste volume of the MSWLF – Phases 1 & 2 (Cells 1 through 4)
based on the latest survey in 2016.
ii. The average annual waste disposal rate for the past 5 years.
iii. The remaining capacity and the operating life of the MSWLF including the Phase
2, Cell 4.
iv. The description(s) of a new or additional non-disposal solid waste management
unit (s), if any, that is not described in the previously approved Facility Plan
[Rules 15A NCAC 13B .1619(b)(1) & (d)(1)(B)] (see Comment No. 2).

4. The Permit to Construct (PTC) for the MSWLF – Phase 2 (DIN 8572) expired on
October 08, 2015. Please provide the status of construction of the Phase 2, Cell 5. If the
Phase 2 is under construction, the request for an approval of new PTC for Phases 2, Cell
5 shall be a portion of the Permit Amendment Application. If the Cell 5 is completed
constructed, please submit the SWS a copy of the rule-required Construction Quality
Assurance Report including as-built drawings for a review and approval.

5. Please add the following info to the Facility Plan drawing:
i. The Phase 2, Cell 4 was completely constructed and is currently receiving waste
for disposal. The waste boundary of the Cell 4 shall be delineated on the drawing
according to the as-built drawing. Please revise the drawing accordingly.
ii. Used/scrap Tire Unit which is on the west side of the Residential Drop-Off Area.
iii. The water bodies of the Grassy Greek and the railroad lines & easements owned
by the Norfolk Southern Railroad which are bisect the closed (Unit 1) and active
landfill (Landfill Expansion Area) units.
iv. The location of the Sara Lee Corporation office complex which is mentioned in
the landfill gas monitoring plan.

Operations Plan
6. (Waste Receiving And Inspection) Please provide additional info regarding waste
inspection:
i. Please describe the area to be used for conducting random waste screening. The
last sentence of this Section states “if no unacceptable waste is found, the load
Ms. Jan McHargue, PE
June 29, 2016
DIN 26330
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will be pushed to the working face …”; the waste screening area is likely adjacent
to the working face.
ii. Please define the described “paint filter test” [referring Rule 15A NCAC 13B
.1626(9)(c)].

7. (Waste Determination Process)
i. The referenced Rule 15A NCAC 13B .1626(f) doesn’t exist and is likely a typo.
Please provide the correct rule reference.
ii. Should the DWM be involved into the review and approval processes? Please
clarify.

8. (Prohibit Waste Types)
i. Pursuant to the 30-year Franchise Agreement granted to the Commission,
radioactive waste must be added to the prohibit waste list for this landfill. Has
this landfill installed a monitoring device in the scale house or other appropriate
area to monitor/screen if radioactive waste that is placed among other wastes
inside a waste-loading vehicle is attempted for disposal of at the landfill? Please
clarify.
ii. The Section 5.3.3 is not available in the Operations Plan. Please provide the
procedures to handle and manage the friable asbestos received at the landfill.
iii. Please describe the non-friable asbestos waste disposal procedures at the landfill
such as the pre-notification requirement (if required), landfill cell preparations,
and disposal location and procedures [Rule 15A NCAC 13B .1626(1)(d)].
iv. The Operations Plan states that the landfill accepts non-friable asbestos waste for
disposal, and the friable asbestos waste is considered as prohibited waste for
disposal. Is there an accredited operator/personnel on-site to identify and/or
differentiate these two types of asbestos wastes? Or should the Operations Plan
require that the proper documentation identifying the waste classification,
certified by an accredited individual is accompanied with waste. Please clarify.

9. (Hazardous Waste Contingency Plan)
i. Please add the notification time requirement of reporting attempted disposal of
hazardous waste at the landfill [Rule 15A NCAC 13B .1626(1)(a)].
ii. The first paragraph states that “An attempt was made to dispose of waste that was
generated outside the permitted Service Area.” Should the purpose of this
contingency plan be regarding the attempt to dispose of hazardous waste at the
landfill? Please clarify.

10. (Concrete, Asphalt, and Brick Operations) Please provide the additional info of this unit.
i. The footprint (in acreage) of this beneficial fill unit.
Ms. Jan McHargue, PE
June 29, 2016
DIN 26330
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ii. Please add the unit is gated and locked when it is not used.
iii. Please add the proper signs to direct traffic flows and disposal are established in
and adjacent to the unit.
iv. Any rebar/reinforcement protruding out of the concrete block should be cut and
flush with the concrete surface. Please add this requirement to the Section.

11. (Air Quality Control) Please provide addition info.
i. Please describe if the USEPA green-house gas reporting and compliance at the
landfill facility [Rule 15A NCAC 13B. 1626(5)].
ii. The landfill gas collection and control systems (LFGCCs) have been installed in
the closed landfill units (Unit 1). Has the system been expanded to the active
MSWLF – Phase 1? If so, please provide (a) the as-built drawing to show the
locations and identifications of the existing gas extraction wells, the gas piping
runs/alignments, condensation traps, control valves, etc. and (b) the copy of the
current and valid NC Air Quality Permit.
iii. The standardized fire occurrence notification report can be directly downloaded
from the SWS web page at the link http://ncdenr.s3.amazonaws.com/s3fs-
public/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf. If
the Commission wants to use this form, please append a hard copy of the
notification report to the Operations Plan.

12. (Spreading and Compacting Program) Any windblown debris must be collected at the
conclusion of each working day [Rule 15A NACA 13B .1626(11)(c)]. Please add the
frequency requirement to this Section.

13. (Leachate Management) Please provide the addition info associated with Leachate
Management:
i. Please provide a drawing to show the existing leachate management devices in the
landfill facility including leachate piping (headers and laterals) runs/alignments in
each cell, Sumps 1 & 2, the alignment of the force main from sumps via a conduit
underneath the Grassy Creek and the railroad lines & easements owned by the
Norfolk Southern Railroad to the on-site leachate storage tank, the leachate
sample location, the leachate discharge point/connection to the city sewer system.
ii. Describe the number and the capacity (full capacity and operational capacity) of
the existing leachate tank(s).
iii. Provide a copy of an agreement/approval letter dated September 13, 2005 that
shows a waste water treatment plant owned by City/County is accepting and will
accept the leachate generated from this landfill without pre-treatment or testing
requirements except equalization in the storage tank.
Ms. Jan McHargue, PE
June 29, 2016
DIN 26330
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iv. Provide the data of the average monthly volume of the leachate generated from
the landfill for the past 5 years – from 2011 through 2016 [Rule 15A NCAC 13B
.1619(e)(4).
v. Describe the record keeping requirement [Rule 15A NCAC 13B .1680(b)(2)].
vi. Describe the inspection and maintenance and record-keeping requirements of the
leachate storage facility [Rule 15A NCAC 13B .1680(c)(4) & (5)].

14. The Operations Plan must describe the protocols and procedures to:
i. Control disease vectors [Rule 15A NCAC 13B .1626(3)].
ii. Implement drainage control measures to divert surface water (run-on) toward the
operational area and to prevent solid wastes from being in standing water [Rule
15A NCAC 13B .1626(8)].
iii. For preparing fire-fighting plan, please describe the procedures/protocols to
handle and manage “hot load” in the following scenarios:
a. A waste truck carrying visible “hot load” is approaching the on-site scale
house.
b. A waste truck carrying visible “hot load” is inside the landfill facility but is
not reaching the landfill working face.
c. A waste truck carrying visible “hot load” is found at the landfill working face.

15. (Record Keeping Program) Please add the following record/report to this Section [Rule
15A NCAC 13B .1626(10)]:
i. The amounts by weight of solid waste received at the facility including source of
generation according to the scale-house data.
ii. Financial Assurance data.

Closure Plan
16. (Cap System Background) According to the Permit to Operate for the landfill dated
October 18, 2011 (DIN 15266), the MSWLF landfill encompasses 102-acre waste
footprint and has the approved total gross capacity of 13,700,000 cubic yards. However,
this Section describes that “the total landfill volume at completion will be 12,200,000
cubic yards for the 90+/- acres foot print. Please clarify the discrepancy.

17. (Closure Verification) The correct reference of the recordation requirement is in Rule
.1267(c)(8). Please make necessary correction.

18. Please provide the construction assurance plan (CQA Plan) and technical specifications
for the geosynthetic liner (likely LLDPE), a component of the proposed landfill final
cover system according to Rule 15A NCAC 13B .1624 [Rule 15A NCAC 13B .1627(3)],
and the GRI GM17 (revision dated November 04, 2015) can be used as the good
reference for preparing the CQA plan and the specification.

Ms. Jan McHargue, PE
June 29, 2016
DIN 26330
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19. Please provide the cost estimates for closing the proposed 65-acre landfill according to
Rule 15A NCAC 13B .1629(b)(3). The previously cost estimates for closing 65-acre
MSWLF-Phases 1 & 2 in the approved Permit to Construct Application (DIN 11658) is
$6,986,723.00 in 2009 dollar values. The SWS may accept the final cost of $7,715,682,
in 2016 dollar values, for closure of the 65- acre area, and this final cost is based on the
2009 closure cost of $6,986,723.00 and adjusted for inflation factors from 2010 through
2016 [Rule 15A NCAC 13B .1628(b)].

Post-Closure Plan (PCP)
20. The PCP should have the scopes covering the both closed units (Unit 1) – 181 acres and
active landfill unit (Landfill Expansion Area) -102 acres, encompassing a total of
approximately 283 acres. Please add the area that is subject to the post-closure care
activities to the PCP.

21. (Closure of Storage Tank) The activities of removing all components of the on-site
leachate storage facility in accordance with the approved closure plan shall be completed
within 180 days after liquid collection has ceased [Rule 15A NCAC 13B .1680(f)(2)].
Please add this requirement to this Section.

22. Please provide the cost estimates for post-close care activities at the closed 65-acre
landfill according to Rule 15A NCAC 13B .1629(c)(4). The previously cost estimates for
post-closure cares in the approved Permit to Construct Application (DIN 11658) is
$2,707,269.00 in 2009 dollar values. The SWS may accept the final cost of
$2,989,732.00 in 2016 dollar values for conducting post-closure cares at the closed
landfill 65- acre area and this final cost is based on the 2009 closure cost of
$2,707,269.00 and adjusted for inflation factors from 2010 through 2016 [Rule 15A
NCAC 13B .1628(c)].

23. Please provide the copy of the approved cost estimates for post-close care activities at the
closed 181-acre landfill units (UNIT 1) which was closed in 2005 according to Rule 15A
NCAC 13B .1629(c)(4). The cost must be adjusted for inflation factors from 2005
through 2016.

Financial Assurance
24. Pursuant to Rule 15A NCAC 13B .1628(a)(4), the Commission shall provide the cost
estimates for implementing the approved groundwater corrective action at areas
underneath the closed landfill units (Unit 1), if implemented.

25. Pursuant to NCGS 130A-295.2(h), the Commission shall establish financial assurance
sufficient to cover a minimum of two million dollars ($2,000,000) in costs for potential
Ms. Jan McHargue, PE
June 29, 2016
DIN 26330
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assessment and corrective action at the facility. This financial assurance requirement is in
addition to the other financial responsibility requirements set out for the landfill closure,
post-closure cares, and the existing groundwater corrective action, if implemented, at
closed landfill units (Unit 1).

Water Quality Monitoring Plan (WQMP)
26. In addition to the WQMP for the closed landfill units (Unit 1), please also provide a copy
of the WQMP for the active MSWLF (Landfill Expansion Area) according to the
applicable Rules 15A NCAC 13B .0602 (for surface water monitoring- SW-1& SW-2),
.1630 through .1637 (for groundwater monitoring – MW-12 through MW-22), .1626(12)
(for leachate sampling), and the Drawing 1 – Groundwater Surface Contour Map in the
WQMP.

Landfill Gas Monitoring Plan (LGMP)
27. The following inconsistencies are found in the Plan, please make necessary corrections:
i. (Permanent Monitoring Station Design And Installation) The referenced Drawing
C-8 is not available in the LGMP. The available drawing is the drawing Sheet
00C-02.
ii. (Contingency Plan, the first paragraph on Page 2) The referenced Section 3.0 is
not available in the plan. The Section of Landfill Gas Overview & Regulatory
Action Levels and Table 1 – Compliance Levels of Methane are likely the ones
for references.
iii. (Immediately Action on Pages 2 & 3) The referenced Section 5.1 is not included
in the LGMP.
iv. (Action within 7 Days on Page 3) The referenced Sections 5.2.1 & 5.3.1 are not
included in the LGMP.
v. (Action within 60 Days, on Page 4) The referenced Section 5.0 is not included in
the LGMP.
vi. (LFG Control System Installation and Monitoring) The referenced Sections 4.0 &
6.2 are not available in the LGMP.
vii. (Active Gas Control System) The installed LFGCCs at the closed MSWLF units
is operational. The landfill gas to energy system (LFGTEs) as shown on the
Facility Plan drawing (Sheet 00G-01) is also operating by the third party (Salem
Energy Systems LLC). This Section should describe the existing LFGCCs and
LFGTEs at the landfill facility. Additionally, provide the copies of the NC Air
Quality Permits for the on-site flare(s) and engines, turbines, or compressors
which can be appended to the Operations Plan.

The Commission should submit the SWS a hard copy of the revised portions of the application
document including the responses to the above-mentioned comment and drawings and one
Ms. Jan McHargue, PE
June 29, 2016
DIN 26330
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electronic copy of the entire revised permit application. If you have any questions please contact
myself at 919-707-8251 [e-mail].

Sincerely,
Ming-Tai Chao, P.E.
Division of Waste Management, NCDEQ

cc:
Edward Gibson, P.E., City/County Utilities Michael Plummer, P.E., HDR
Ed Mussler, P.E, Permitting Branch Supervisor Perry Sugg, P.G. DWM
Susan Heim, DWM Deb Aja, DWM
Central Files