4103_CityofGreensboro_WhiteStMSWLFPhaseII_GWCA_DIN27483_20170303

S&ME, Inc. | 8646 W Market St, Ste 105 | Greensboro, NC 27409 | p 336.288.7180 | f 336.288.8980 | www.smeinc.com
March 3, 2017
NCDEQ-DWM-SWS
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
Attention:Ms. Jaclynne Drummond
Reference:EBuffer® Inspection Schedule Revision Request
White Street Landfill, Permit No. 41-03
Greensboro, North Carolina
S&ME Project No. 1584-98-081C
Dear Ms. Drummond:
The Corrective Action Plan (CAP) for the White Street Landfill Phase II, included monitoring of the
phytoremediation system (EBuffers®). These visual inspections originally included monthly inspections of
the trees comprising the Northern EBuffer® and the Southern EBuffer®. The initial monthly frequency
was established to closely monitor the EBuffer® trees following the installation for animal damages,
actual site conditions causing stresses potentially impacting growth, and lastly for tree mortality. During
the initial, juvenile tree growth stages, the frequency of monitoring these conditions is generally the
highest, then diminishes as the EBuffers® become fully established and the trees progress into a mature
growth stage.
The CAP discussed that the fatal flaw characteristics for a site to impede the success of the EBuffers®
include; wildlife, salinity, over hydration, lack of management, and agronomy (weed control). EBuffers®,
particularly in the seedling stage, must be protected from beavers and deer which cut or browse on these
plants. Once planted, the EBuffer® must be maintained and weeds kept mowed in order to prevent weeds
and other vegetation from overtaking and choking out the hybrid poplar seedlings. Furthermore, based
on the heartiness and viability of hybrid poplar trees, it was not anticipated that insects would affect the
young hybrid poplar trees. However, if the saplings were attacked by insects which affect the growth and
sustainability of the trees, appropriate methods to counter the detrimental insects would be implemented.
Furthermore, the CAP stated that the Facility will maintain EBuffers® assessment logs. These logs would
be prepared monthly for the first two years after planting of the EBuffers® is complete. During the third
year following completion of planting the EBuffers® assessment logs will be completed quarterly and
annually thereafter. Each EBuffers® assessment log would contain entries for observed site conditions
including general site conditions, EBuffers® inspections, tree health observations, tree growth
observations, EBuffers® maintenance, and general information.
In conjunction with the EBuffers® assessment logs, the CAP outlined that the Facility will perform an
annual tree growth survival audit. Under this audit, each tree within the phytoremediation system will be
visually inspected to determine if it is: dead or dying, shows limited growth, is established, or shows good
EBuffer® Inspection Schedule Revision Request
White Street Landfill, Permit No. 41-03
Greensboro, North Carolina
S&ME Project No. 1584-98-081C
March 3, 2017 2
growth and appears healthy. This audit will ensure the EBuffers® remain healthy to promote effective
remediation of groundwater quality.
S&ME in consultation with Dr. Louis Licht with ECOLOTREE, reduced the frequency to quarterly, then
semi-annually. For this change S&ME should have previously requested approval for these reductions
from the North Carolina Department of Environmental Quality, NCDEQ-DWS-SWS. With this letter S&ME
on behalf of the City of Greensboro, requests approval for the EBuffer® Inspections to be as follows:
1)Twice per year conduct full inspections (audit) of the EBuffers®, one during the spring new growth,
and the other during late summer to early fall before the tree leaves begin to change color. These
inspections will include:
a)Completion of phytoremediation assessment logs for the Northern and Southern EBuffers®. Each
EBuffers® assessment log will contain entries for observed site conditions including general site
conditions, EBuffers® inspections, tree health or mortality observations, tree growth observations,
EBuffers® maintenance, and any other pertinent information.
2)Monthly EBuffer® inspections should include:
a)Visual observations for potentially damaging animal activities, primarily beaver damage and deer
rubs.
b)Visual observations to assess for the need to mow the grass between the rows of trees and along
the outer perimeter trees, as wells as the need for weed control around the base of the trees.
The above outlined inspections provide for a sufficient and appropriate level monitoring of the EBuffers®
at the White Street Landfill, given the maturity of the trees; while controlling related monitoring costs
without impacting the predicted performance of the EBuffers®.
Sincerely,
S&ME, Inc.
Edmund Q.B. Henriques, L.G.David Loftis, P.E.
Senior Geologist/Project Manager Senior Engineer