4002_GreeneCoCDLF_Comment_LOSPermitApp_DIN27679_20170428

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Friday, April 28, 2017 11:22 AM
To:'[e-mail]'
Cc:Wayne Sullivan ([e-mail]); Sugg, William P; Williams, Ray
Subject:Comments on Life-of-Site Permit Application, 40-02, DIN 27679
Dear Mr. Jones: DIN 27679

The Solid Waste Section (SWS) completed a review of the life-of site permit application (DIN 27650) for the
Greene County CDLF on top of the closed unlined MSWLF unit, which was prepared by MESCO. Based on
the review, the SWS has several comments on the permit application:

Operations Plan
1. (Section 1.2.1.b) The Facility Compliance Inspection Reports, dated May 11, 2016 and July 27,
2016, reported that the Greene County C&DLF Facility did not accept asbestos containing material or
waste (ACM) for disposal. Please add the fact to this subsection. However, in the future the County
will take ACM for disposal, the described procedures in this subsection is acceptable.

2. (Section 1.2.1.l) The Facility Compliance Inspection Reports, dated May 11, 2016 and July 27,
2016, reported that inert materials, consisting of clean concrete, brick, and used asphalt, recovered from
the received waste stream has been stockpiled in an area adjacent to Small Type 1 Composting
Area. Please add the operation requirements of this Treatment and Processing (T&P) Unit to the
Operations Plan including the following information, but not limited to:
i. Operation of this T&P unit, as defined in Rule 15A NCAC 13B .0101(49), must meet the
requirements stated in Rules Rule 15A NCAC 13B .0301 & .0302
ii. The location of this T&P Unit must add to the Facility or Operations plan drawings.
iii. Description of the acceptable wastes to be recovered from the permitted waste stream.
iv. The size (in acreage) of this unit and the maximum volume (in cubic yard) of the stockpile
(including both waste stockpiles & the final products).
v. The operation requirements for handling & managing “Recycled” or “Recovered” Materials, as
defined in NCGS 130A-290(a)(24) and (26), respectively must comply with NCGS 130A -
309.05(c).
vi. Descriptions of how to treat & process the recovered/recycled material and to utilize the products
derived from the recovered/recycled material.

3. (Section 1.7, Foam Coating, item 4, on Page 23) Use of the mixture of non-hazardous latex or water
base paints with foam coating as an ADC for a unlined sanitary landfill is not an approved ADC
according to the guidance document titled “Approved Alternative Daily Cover Materials for Use at
Sanitary Landfills” dated January 7, 2014 (DIN 20365). If the proposed ADC in this Section has been
approved to be applicable at any unlined sanitary landfill in the State of North Carolina, please provide
the facility name and permit number and approved document identification number (DIN); otherwise,
please remove this proposed ADC from the section. If the County plans to use this ADC, please submit
the SWS a pilot study/demonstration plan for an approval for applying this proposed ADC at the landfill
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working face for a short-period time (no more than 6- months) to determine if the proposed ADC is an
acceptable one for long-term usage.

4. The following documents are not included in the Operations Plan, please provide the rule required
documents:
i. Waste Screening Plan [Rule 15A NCAC 13B .0544(e)].
ii. Fire Occurrence Report, which can be downloaded from the web link: NC SWS Fire Occurrence
Report Form

Closure & Post Closure Plan
5. (Section 3.2) The post-closure costs must include the costs for:
i. The on-going corrective action program to clean up impacted groundwater underneath the closed
unlined MSWLF unit.
ii. Potential assessment and corrective action (PACA) at the facility which is additional to the costs
for the on-going groundwater corrective action program [NCGS 130A-295.2].

GW & Surface Water Monitoring Plan
6. Please submit an updated, stand-alone Water Quality Monitoring plan for the facility. The current
approved sampling & analysis plan was last revised in February 2010 and contained as Appendix B in
the revised Approved Corrective Action Plan (DIN 9670). Include any changes in monitoring that have
been approved since 2010 to reflect the current corrective action monitoring at the facility.

Landfill Gas Monitoring Plan
7. LFG Plan General: Please submit a stand-alone Landfill Gas Monitoring plan for the facility. The most
recent approved plan was contained as Appendix C in the revised Approved Corrective Action Plan
(DIN 9670) dated February 2010. Update this plan following the current plan format from our
guidance.

8. H2S: Due to the nature of materials disposed in them, C&D landfills are a potential source of the
explosive gas hydrogen sulfide (H2S). The plan needs to be amended to also include hydrogen sulfide
gas (H2S) monitoring. Add H2S monitoring along with regulatory action limits for hydrogen sulfide
(4% by volume for 100 LEL and 1% by volume for 25% LEL, respectively).

9. LFG Monitoring Locations: include a map showing LFG monitoring locations (wells, probes and/or
buildings).

10. LFG Plan Contingency: Please include a Contingency section about how to address LFG readings
detected above regulatory limits.

11. LFG Monitoring Data Form: Include a copy of the 2017 updated LFG monitoring form (attached),
which includes H2S requirements.

Appendix A - Written Facility Plan
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12. It is evident that the County increases the permitted gross capacity of 434, 135 cubic yards (CY) as
described in “General” to 471,466 CY as shown on the “Landfill Capacity.” Please explain why
inconsistent total gross capacity is present in the plan.

13. This C&DLF unit has been receiving permitted wastes for disposal since 1997, why the data (waste
disposal rate) in Fiscal Year 2008-2009 is used for calculating life expectancy. Should the data from
1997 through 2016 be used for the calculation?
Please provide the SWS a written responses to the above-referenced comments which should be incorporated
into the revised permit application. Thank you for your cooperation on this matter. Have a wonderful weekend.

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

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