7607_GreatOakMSWLF_Comments_OperationPlan_DIN27069_20161129

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Tuesday, November 29, 2016 1:27 PM
To:John Workman
Cc:Sharon Korleski; 'Glenn, Albert'; [e-mail]; Mussler, Ed;
Murray, John E; Patrone, John
Subject:request of revising Operations Plan, Great Oak MSWLF, 76-07, DIN 27069
Attachments:Response Letter to NCDEQ_10-17-2016.pdf
Dear Mr. Workman: DIIN
27069

The Solid Waste Section (SWS) was informed that the Cell 1A of the Great Oak MSWLF, Permit # 76-07 and
the supporting infrastructures are near completion. The tentative schedule for the landfill to receive permitted
waste for disposal at the Cell 1A is this coming December. To assist Waste Management (the permittee) in
meeting the tight schedule, the SWS has completely reviewed the partial and progressive Construction Quality
Assurance Report for Cell 1A submitted in October and November 2016. The SWS is looking forward to
receive the completed CQA Report for Cell 1A; in the meantime, tying-up some loose ends in the Operations
Plan should be subject to your attention.

One of the responses dated October 17, 2016 (see Attachment) to the SWS Comment No. 3 stated that the pump
& haul of leachate disposal approach that is mentioned in the Operations Plan is subjected to deletion from the
plan; and SCS Engineers on your behalf requested S&ME to submit a revised plan. As of today (November 29,
2016) the SWS does not received the revised plan. Please submit this revision.

Additionally, after recently revisited the Operations Plan the SWS found several areas are also required your
attentions to revise, clarify or provide more detail information; they are:

1. Pursuant to North Carolina General Statue (NCGS) 130A-295.6(g) the permittee must submit a waste
screening plan, which shall identify measures adequate to ensure compliance with State laws and rules
and any applicable local ordinances that prohibit the disposal of certain items in landfills. The plan shall
address all sources of waste generation. The plan is subject to review and approval by the SWS. The
Appendix A of the Operations Plan, in a minimum, should include random screening number of waste
loads required (by time period, number of trucks, or by throughput), the personnel credential/training to
conduct the screening & to identify non-conformance wastes (including liquid/aqueous wastes identified
by USEPA test method) or prohibited waste streams, reporting requirements according to Rule 15A
NCAC 13B .1626. A typical waste screening form (s) In Appendix B may be referenced to the
narratives in Appendix A.

2. Any miscellaneous operations, such as operating recovered material and recyclable material units at the
landfill facility, are to be conducted (allowed by the Franchise Agreement), they are not
mentioned. However, this part [according to NCGS 130A-309.05] can be added to the operations plan
later as a request of a permit modification (?) when the unit is planning to be operated at the
landfill. The location of each unit must be shown on the Facility Plan and/or Operations Plan drawings.
The permittee shall not operate these units without the SWS approval according to the Franchise
Agreement.

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3. Section 3.2.5 – Cover. Shredded green waste that is considered as yard trash as defined in NCGS 130A-
290.(a) can NOT be applied as ADC and disposed at landfill. Please remove this application from the
revised Operations Plan. In fact, the MSWLF can use any ADC described in the SWS guidance
document titled “Approved Alternative Daily Cover Materials for Use at a Sanitary Landfills”. The
document can be downloaded at the following link http://deq.nc.gov/about/divisions/waste-
management/waste-management-permit-guidance/solid-waste-section.

4. Section 4.2.4 Leachate Storage Tanks. The routine inspections shall be in compliance with 13B
.1680(c)(4) and (c)(5). The inspection (personnel and frequency), maintenance, and documentation
requirements must be added to this section.

5. Since the single-wall leachate forcemain section from pumping station to the sanitary sewer manhole (s)
which are located inside the landfill facility. The as-built drawings of the layout/alignment forcemain
and locations of the manholes must be shown on the revised Operations Plan drawings. Routine
inspection of the forcemain and manhole for identifying spillage or leakage may be warranted. Should
spillage or leakage be discovered by the personnel conducting routine inspection, a verbal and written
notification followed by an action plan including assessment and/or remediation shall be submitted to
the SWS in a reasonable time frame. Please add the above-mentioned requirements to a inspection and
reporting plan appended to Section 4 of the Operations Plan.

6. And, if warranted, a radiation contingency plan should be appended to the revised Operations Plan.

The SWS appreciates your cooperation submitting the revised Operations Plan; a hard copy and an electronic
copy (in pdf format) are required. Please contact me if you have any question of the above-mentioned requested
items

Best regards,

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

Ming Chao
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Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.