4103_WhiteStyreetCDLF-RevisedLOSApp_DIN27805_20170516

May 16, 2017
Mr. Ming Chao
North Carolina Department of
Environment Quality
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27699-1646
RE: Response to Comments on Life-of-Site Permit Application
White Street Construction and Demolition Debris Landfill (CDLF) on Top of the Closed
Unlined Municipal Solid Waste Landfill (Phase II)
Guilford County, North Carolina
Permit No. 4103-CDLF-1998, Document ID No. (DIN) 27317
Dear Mr.Chao,
HDR is in receipt of your letter dated February 1, 2017 which outlines comments related to the
permit application for a life-of-site permit as outlined in the December 22, 2016 Permit Amendment,
White Street Construction and Demolition Landfill, City of Greensboro, North Carolina.
Each comment is repeated below with the corresponding response in italics:
1. Please provide the following information to the Engineering Plan.
i. (Section 2.1) The waste footprint (in acreage) of the unlined closed MSWLF unit
(overlain by the active C&DLF unit) & the active C&DLF unit, respectively.
Section 2.1 of the Engineering Plan has been revised to include acreage information.
ii. (Section 2.2) According to Rule 15A NCAC 13B .0539(a) the horizontal buffer for a
C&DLF unit must meet the requirements stated in Rule 15A NCAC 13B .0540(1). Please
revise the referenced rule in this section and buffer distance requirements accordingly.
Section 2.2 of the Engineering Plan has been revised as requested.
iii. (Section 2.4) Please provide the capacity information:
a. The gross capacity of the C&DLF unit, as defined in Rule 15A NCAC 13B
.0537(e)(2)(B), shall be the same volume as the one [2,525,443 cubic yards (CY)]
which is stated in the permit date March 30, 2012 (DIN 16015). Please state the
correct gross capacity of the landfill unit.
Section 2.4 of the Engineering Plan has been revised. The March 30, 2012
permitted gross capacity is 2,525,443 cubic yards. The gross capacity based on the
hdrinc.com
440 S Church Street, Suite 1000Charlotte, NC 28202-2075
704.338.6700
City of Greensboro | White Street C&D Landfill Response to Comments on Life-of-Site Permit Application
current development plan is 2,370,000 cubic yards. Currently the City of
Greensboro has no plans to modify the current development plan but reserves the
right to recapture the additional space if needed in the future.
b. According to the drawing Sheet C-01- Fill Plan, the C&DLF unit will be operated by
series of fill sequences - Lift 1 through Lift 6, which are not consistent with those
specified in the Permit Condition No. 6, Attachment 3 of the current permit dated
March 30, 2012 (DIN 16015). If the City proposes to modify the approved 5-Lift to
6-Lift fill sequences, please provide the operating capacity (in cubic yard) of each of
the proposed six (6) lifts. Please note that operating capacity of the final lift (Lift 6)
should include the volume of the final cover system described in the Appendix F -
Closure Plan.
Drawing Sheet C-01, Fill Plan, in Appendix H has been revised. This application
identifies the filling plan for this life of site permit. The C&D material is filled in
approximately 10 foot lifts across the active area. Actual sequence and lift
thickness may vary based on site conditions.
c. Please provide the volume of soil required for the landfill operation and closure
activities according to Rule 15A NCAC 13B .0537(e)(2). The detail calculations &
assumptions to determine the soil quantities should be included in the section. Will
there be sufficient soil from the on-site borrow pits to cover the operations and
closure of the landfill unit? Please clarify.
Section 12.1 of the Operations Plan has been revised to provide soil requirements
for operational use. Anticipated soil for closure activities is provided in Section 1.4
of the Closure/Post-Closure Plan. Soil materials will need to come from on site
stockpiles and/or off-site.
2. Please provide the additional information to the Operations Plan.
i. (Section 12.1) According to Rule 15A NCAC 13B .0542(f)(l), the City must "cover the
solid waste with six inches of earthen material when the waste disposal area exceeds
one-half acre AND (not "or") at least once weekly." Please revise the cover requirement
in this section accordingly.
Section 12.1 of the Operations Plan has been modified as requested.
ii. (Section 12.2) According to Rule 15A NCAC 13B .0542(f)(2) and Section 19 of the
Operations Plan, an inactive area without receiving permitted wastes for disposal for
THREE (3) months, not 12 months, shall be covered by an intermediate cover. Please
revise the frequency for placing intermediate cover in Section 12.2.
2
City of Greensboro | White Street C&D Landfill Response to Comments on Life-of-Site Permit Application
Section 12.2 of the Operations Plan has been modified as requested.
iii. (Section 14.0) The City should also monitor the concentrations of hydrogen sulfate at
the C&DLF unit. Additionally, the SWS requests the City submit a separate cover or
stand-alone landfill gas monitoring plan for this C&DLF unit according to the guidance
document which can be downloaded from the following link. Please provide the landfill
gas monitoring plan for this C&DLF unit.
https://ncdenr.s3.amazonaws.com/s3fs-
public/Waste%20Management/DWM/SW/Field%20Operations/Environmental%20Monit
oring/LandfillGasMonitoringGuidanceDocument.pdf
Section 14.0 of the Operations Plan has been updated to include hydrogen sulfide gas.
The Landfill Gas Monitoring Plan has been added as Appendix G.
iv. (Section 15.0) Does each landfill equipment/machinery equipped with a fire
extinguisher? Please clarify. Additionally, the SWS has a standard fire incidence report
form can be used for reporting a fire/explosion, should it occur. If the City agrees to use
the form, please download and append the form to the Operations Plan. The web link is
http://ncdenr.s3.amazonaws.com/s3fs-
public/Waste%20Management/DWM/SW/Forms/FireOccurrenceReport.pdf
The city has a fire extinguisher in each piece of landfill equipment and machinery. The
Fire Occurrence form has been added to the Operations Plan as requested.
v. (Section 16.0) Please state the landfill service area(s) - the City of Greensboro and
Guilford County which is consistent to the permit dated March 30, 2012 (DIN 16015).
Section 16.0 of the Operations Plan has been modified to state the service area is the
City of Greensboro and Guilford County.
vi. (Section 16.2) To clearly understand the frequency of random waste screen at the
C&DLF unit, please state the minimum truck per day will be subject to waste screening.
According to latest Facility Compliance Inspection Report for the C&DLF unit dated
October 26, 2016, Comment No. 16 states that the facility is required to conduct a
minimum of one (1) waste screen per day. If the City will continue this practice, please
state the fact to this section.
Section 16.2 of the Operations Plan Section has been modified to state a minimum of
one truck per day will be screened.
vii. (Section 19.0) To be consistent with the practice stated in Section 12.2 and Rule 15A
NCAC 138 .0542(f)(2), please clear define the "vegetative cover" in this section.
3
City of Greensboro | White Street C&D Landfill Response to Comments on Life-of-Site Permit Application
Section 19.0 of the Operations Plan has been modified to define vegetative cover.
viii. (Section 21.0) A landfill gas collection and control system (LFGCCs) is operating at this
landfill unit (Phase II). Please describe the well field [ wells (numbers and depths),
condensate traps, air piping (gradients & sizes), operation and maintenance
requirements including the responsible parties & contact info, NC air permit number(s),
condensate removal & disposal procedures, measures to protect the system from
interrupting active landfill operations, and etc.
This facility operates under NCDEQ Air Quality Permit No.08830T06. A copy of the
permit has been added to Appendix A, Related Correspondence. For specifics of the
system and design please contact the NCDEQ Division of Air Quality.
ix. (Section 21.0) Please provide the procedures or corrective measures to prevent
leachate outbreak(s) on the side slope(s) of the landfill units - both MSWLF & C&DLF
units, should it occur. The procedures/corrective measures are required for the post-
closure period as well.
The landfill prevents leachate breakouts by maintaining the proper thickness of
intermediate cover and repairing erosion rills as necessary. In the event of a leachate
breakout the landfill staff would place additional soil cover in the area and re-vegetate.
Section 21 of the Operations Plan has been revised to include this information.
3. Please provide the additional information of the Closure and Post-Closure Plan.
i. Please describe the landfill gas vents/wells to be installed at the final cover system
including the frequency, such as one vent/well per acre. The typical drawing of a gas
vent/well must be provided to the Closure Plan drawing(s).
The Closure Plan Section 1.2 has been modified to include the gas venting system. A
landfill gas well detail has been added as Appendix F-2 of the Closure Plan.
ii. (Section 1.10) Closure cost estimate is placed in Appendix F-1, not E-1. Please correct
the typo.
Section 1.10 of the Closure/Post Closure Plan has been corrected.
iii. (Section 2.1) Please provide the extent (in acreage) of the landfill unit (including the
closed unlined MSWLF and the C&DLF unit) that will be subject to 30-year post-closure
cares.
Section 2.1 of the Closure/Post Closure Plan has been revised. The landfill unit is 135
acres. The Phase II MSW was closed in 1998. The 90 acre C&D landfill portion currently
consists of 59 closed acres and 31 active acres.
4
City of Greensboro | White Street C&D Landfill Response to Comments on Life-of-Site Permit Application
iv. (Section 2.4) The operation of the existing LFGCCs is likely to be terminated in the end
of the 30-year post-closure period; therefore, please provide a decommission plan for
the system which includes, in a minimum, removal of system components (including the
flare station) to an off-site location for recycling or disposal, disposal of in-line gas
condensate & wastes, capping gas/condensate lines, gas well abandonment
procedures, restoration of the final cover system, etc. The decommissioning costs must
be included in the post closure estimates. Please be advised that the LFGCCs may be
owned or operated by a third party, but the City is the landfill property owner/operator
who is ultimately responsible for the operation, maintenance and decommissioning of
the LFGCCs.
To decommission the LFGCCs, the wellheads will be removed to allow passive venting,
the condensate lines will be drained and capped and the flare and blower will be sold or
recycled. HDR has assumed the value of the flare and blower will offset the cost to pull
the wellheads and therefore the decommissioning costs are negligible.
v. (Section 2.4) Please describe the maintenance requirements of the landfill gas
monitoring system/network (8 gas wells and 4 surface according to Drawing CD-79B) in
consistent with the cost estimate item.
Section 2.4.5 of the Closure/Post Closure Plan has been modified to address both
groundwater and gas well maintenance.
vi. (Section 2.5) Please add the inspection frequencies and requirements of the landfill gas
monitoring system/network.
Table 2 in Section 2.5 of the Closure/Post Closure plan has been modified to address
the landfill gas monitoring system/network inspection frequencies and requirements.
vii. (Section 2.7) Post-Closure cost estimate is placed in Appendix F-1, not E-1. Please
correct the typo.
Section 2.7 of the Closure/Post-Closure Plan has been corrected.
4. (Appendix F-1)
i. Cap Maintenance Item should include costs for correcting cap settlement / subsidence
as described in Section 2.4.3 of the Post-Closure Plan.
Settlement and subsidence directly affects the surface water flow and erosion on the
cap. Therefore, cost for correcting cap settlement/subsidence has already been included
in the Erosion Control and Surface Water Control line items.
5
City of Greensboro | White Street C&D Landfill Response to Comments on Life-of-Site Permit Application
ii. The costs associated with semi-annual surface water monitoring/sampling (at five
locations) are not included in the post-closure estimate. Please provide the costs.
The cost of surface water monitoring and sampling has already been included in the
“Groundwater Sampling/Lab and Report (semiannual)” line item. The title of that line
item has been updated to “Groundwater and Surface Water Sampling/Lab and Report
(semiannual)” in order to clearly define the surface water inclusion.
iii. Pursuant to NCGS 130A-295.2(h), the City shall include two million dollars for potential
assessment and corrective action at the landfill facility to the local government financial
test. This cost is additional to the one for on-going groundwater correction activities at
the landfill facility.
See “Other: Assessment Corrective Action – Permit 41-03” line item listed in Appendix
F1 in the amount of $2,118,712.
iv. According to the letter dated November 15, 2016 issued by the City, the estimated cost
for the on-going groundwater correction at the landfill facility is $1,567,941 in 2012-dollar
value. The inflation factors from 2013 through 2016 (1.018, 1.015, 1.014, and 1.010,
respectively) shall be used for adjust the 2012 cost for the approved correction activities.
The factors can be downloaded from the link http://deq.nc.gov/about/divisions/waste-
management/solid-wastesection/financial-assurance-for-solid-waste-management-
facilities
The cost for groundwater correction in 2016-dollar value is approximately $1,659,216,
but it may be subject to change pending the approval of the SWS (Referring the
enclosed comments issued by SWS Compliance Hydrogeologist on January 11, 2017).
Please revise the cost in the local government financial test accordingly.
See updated Summary of Financial Assurance letter dated 9-Mar-17 in Appendix F1 for
response. The correct inflation factors have been used; the principle amount as been
decreasing since 2012 due to the task being completed in 2012 and thus entering the 30
year compliance period.
5. Appendix G -Drawings
i. (Sheet C-01- Fill Plan) Please address the following comments on this drawing:
a. The thickness of "existing intermediate cover" shown on the Typical Cap System is
6 inches, which is inconsistent with that (12 inches) described in the section of the
Operations Plan. Please clarify.
6
City of Greensboro | White Street C&D Landfill Response to Comments on Life-of-Site Permit Application
Intermediate cover is required to be a minimum of 12 inches thick. The City plans
to reclaim the top six inches for soil cap material. Section 12.2 of the Operations
Plan has been modified to state this.
b. Please indicate/note the maximum side slope of the final cover system is four
(horizontal) to one (vertical) on the cross-section drawings.
Sheet C-01 has been revised as requested.
c. In the Note Field, please use the correct volume of the approved total gross
capacity of 2,525,443 CY consisting operating capacity (volumes of wastes &
periodic & intermediate cover material) and volume of the final cover system
(referring Comment No. 1 iii).
The Sheet C-01 notes have been revised as requested.
d. Have the closed areas (a total of 34 acres) been incorporated into the Site Layout
& Cross-Section drawings? Please clarify.
Closed areas have been incorporated into the Overall Site Plan (CD-77B).
ii. (Overall Site Plan, CD-77B) Please provide the following information on this drawing:
a. The waste footprint (in acreage) of the unlined closed MSWLF (Phase II).
Sheet CD-77B has been revised as requested.
b. The waste footprint (in acreage) of the remaining active C&DLF unit on top of the
MSWLF (Phase II).
Sheet CD-77B has been revised as requested.
c. The waste footprint (in acreage) of the permanently closed C&DLF unit (Part I
Closure - 8 acres in 2013 & Part 2 Closure - 26 acres in 2015, respectively).
Please use different legends on the drawing to differentiate the active and
permanently closed C&DLF unit. The provided information on the drawing will be
incorporated into the new life-of-site permit and approval processes of the financial
assurance.
Sheet CD-78B has been revised to differentiate the active and closed C&D unit.
6. The Solid Waste Section (SWS) Compliance Hydrogeologist has some comments on the
groundwater corrective action at the C&DLF unit/closed unlined MSWLF (Phases II) which is
enclosed in this letter for you to review and respond.
7
City of Greensboro | White Street C&D Landfill Response to Comments on Life-of-Site Permit Application
Questions from the SWS Compliance Hydrogeologist have been included in this response
letter, along with the corresponding responses.
i. I understand that monthly inspections for the phytoremediation stand are not being
conducted in accordance with the approved CAP, and there has not been written
approval from the Section of this deviation. Please clarify.
A request for revision in the EBuffer inspection schedule was submitted to NCDEQ and
approved on March 7, 2017. An excerpt from the approval letter is provided below; the
full request and approval letters have been added to Appendix A of this permit
application.

“…The City of Greensboro is requesting the following regarding changes to the
inspections for the Northern and Southern Ebuffers (Phytoremediation stands):
• Twice per year conduct full inspections of the Ebuffers, one during the
Spring new growth, and the other during late Summer to early Fall before
the trees begin to change color. A phytoremediation assessment log for
the Northern and Southern Ebuffers would be completed at this time.
• Monthly inspections of the Ebuffers including visual observations for
animal damage, the need to mow the grass between the rows of trees
and along the outer perimeter trees, and the need for weed control around
the base of the trees.

As a result, the Ebuffer Inspection Schedule Revision Request is approved as
described…”
ii. The last monitoring report received for the April 2016 monitoring event indicates a 2B
surface water exceedance of VC within the sample collected from SMW3. Please
determine how the City is going to address this surface water concern since this surface
water monitoring location is being used to determine the effectiveness of the
phytoremediation stand near well II-9.
SMW-3 is a groundwater Sentinel Monitoring Well and not a surface water
sample. Jaclynne Drummond informed the City of Greensboro that no action is required.
iii. The last CAER submitted was in May 2012. CAERs are submitted every five years, and
therefore the next CAER is due this year. What is the status of this submittal so it may
be incorporated within the life of site permit
The City has recently changed environmental consultants and as a part of this change
the CAER report is scheduled to be completed before the end of the 2017 calendar year
(likely before September 2017).
8
City of Greensboro | White Street C&D Landfill Response to Comments on Life-of-Site Permit Application
iv. An updated cost for the ongoing groundwater corrective action in 2016 dollars for
financial assurance is required.
A copy of the City of Greensboro Financial Assurance, previously submitted to the state
of North Carolina is included in this as Appendix F1.
If you have any questions regarding this permit amendment request, please do not hesitate to
contact me at 704.338.6843.
Sincerely,
HDR Engineering, Inc. of the Carolinas
Michael D. Plummer
Project Engineer
Enclosures
cc: Jason Jernigan, Greensboro (with enclosures)
Richard Lovett, Greensboro (with enclosures
9

Permit Amendment
White Street Construction and
Demolition Landfill

Greensboro, North Carolina
December 2016
Revised May 2017

HDR Engineering, Inc. of the Carolinas
440 S Church Street, Suite 1000, Charlotte, NC 28202-2075 704.338.6700 NC License F0116

City of Greensboro | White Street Landfill – Permit AmendmentContents

Contents
Appendix A – Related Correspondence
Appendix B – Engineering Plan
Appendix C – Operations Plan
Appendix D – Water Quality Monitoring Plan
Appendix E – Construction Quality Assurance (CQA) Plan
Appendix F – Closure/Post-Closure Plan
Appendix G – Landfill Gas Monitoring Plan
Appendix H – Drawings

City of Greensboro | White Street C&D Landfill – Permit Amendment Appendix A – Related Correspondence

A
Appendix A – Related
Correspondence

NCDEQ PTO Issued March 30, 2012
NCDEQ Partial Closure Certification September 3, 2015
NCDEQ Partial Closure Certification February 17, 2014
Local Government Approval May 20, 2008
Title V Air Quality Permit Issued August 7, 2009
EBuffer Inspection Revision Request, March 3, 2017
NCDEQ EBuffer Inspection Approval March 7, 2017

Beverly Eaves Purdue
Governor
August 7,2009
North Carolina Department of Environment and Natural Resources
Division of Air Quality
B.Keith Overcash,PE
Director
Dee Freeman
Secretary
Mr.Robert Morgan
Acting City Manager
City ofGreensboro -Wbite Street Landfill
2503 White Street
Greensboro,North Carolina 27405
Dear Mr.Johnson:
Sl:IDJECT:Air Quality Permit No.08830T06
Facility JD:4101086
City ofGreensboro -White Street Landfill
Greensboro,North Carolina
Guilford County
Fee Class:Title V
In accordance with your completed Air Quality Permit Application tor a Renewal of a Title V permit
received April 22,2008,we are torwarding herewith Air Quality Permit No.08830T06 to the City ofGreensboro
-White Street Landfill,located at 2503 White Street,Greensboro,North Carolina authorizing the construction and
operation,of the emission source(s)and associated air pollution control device(s)specified herein.Additionally,
any emissions activities determined from your Air Quality Permit Application as being insignificant per I5A North
Carolina Administrative Code 2Q .0503(8)have been listed lor infom1ational purposes as an "ATTACHMENT."
Please note the requirements for the annual compliance certification are contained in General Condition P in
Section 3.The current owner is responsible for submitting a compliance certification for the entire year
regardless ofwbo owned the facility during tbe year.
As the designated responsible ofticial it is your responsibility to review.understand,and abide by all
of the tenns and conditions of the attached permit It is also your responsibility to ensure that any person who
operates any emission source and associated air pollution control device subject to any term or condition oflhe
attached permit reviews,understands,and abides by the condition(s)ofthe attacbed permit that are applicable to
that particular emission source.
Permitting Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
2728 Capital Blvd.,Raleigh,North Carolina 27604
Phone:[phone] FAX [phone]!Inlernet:www.ncalLorg
An Equal Opportunity/Affirmative Action Employer -50%Recycled/10%Post Consumer Paper
N~rthCaro1ina
;VaIUfall!!
Me.Robert Morgan
August 7,2009
Page 2
If any parts,requirements,or limitations contained in this Air Quality Permit are unacceptable to you,you
liave the right to request a formal adjudicatory hearing within 30 days following receipt ofthis permit,identifYing
the specific issues to be contested.This hearing request must be in the form of a written petition,confonning to
NCGS (North Carohna General Statutes)150B-23,and filed with both the Office of Administrative Hearings,
6714 Mail Service Center,Raleigh,North Carolina 27699-6714 and the Division of Air Quality,Permitting
Section,1641 Mail Service Center,Raleigh,North Carolina 27699-1641.The form for requesting a fonnal
adjudicatory hearing may be obtained upou request from the Office of Administrative Hearings.Please note that
this pennit will be stayed in its entirety upon receipt of the request for a hearing Unless a request for a hearing is
made pursuant to NCGS 150B-23,this Air Quality Permit shall be final and binding 30 days after issuance.
You may request modification of your Air Quality Pennit tlirough infomlal means pursuant to NCGS
150B-22.This request must be submitted in writing to the Director and must identify the specific provisions or
issues for which the modification is sought.Please note that this Air Quality Permit will become final and binding
regardless ofa request for informal modification unless a request for a heanng is also made under NCGS 150B-23.
The construction of new air pollution emission sonrce(s)and associated air pollntion control
device(s),or modifications to the emission source(s)and air pollntion control device(s)described in this
permit mnst be covered nnder an Air Quality Permit issned by the Division of Air Qnality prior to
construction nnless the Permittee has fulfilled the reqnirements of GS 143-215-108A(b)and received
written approval from the Director of the Division of Air Qnality to commence construction.Failure to
receive an Air Qnality Permit or written approval prior to commencing construction is a violation of GS
143-215.108A and may snbject the Permittee to civil or criminal penalties as described in GS 143-215.114A
and 143-215.114B.
This Air Quality Permit shall be effective from Augnst 7,2009 until Jnly 31,2014,is nontransferable to
future owners and operators,and shall be subject to the conditions and limitations as specified therein.
Should you have any questions concerning this matter,please contact Me.Booker T.Pullen at (919)715-
6248.
on .van der Vaart,Ph.D.,P.E.,
Chief
Enclosure
c:Gregg Worley,EPA Region 4
Winston Salem Regional Office
Central Files
Page 2
Table ofchaJ.l.....ges to existinf!\?~.I!Jli!.J~o.08830'1'05 pcrr~J},~wal application 41 QJ 086.08A:.~~~~~~
,~~:e~~ge ~~',~:;~age NO~_+~~~~~~::~E:~:~of pe'::,anged date,revIsed ~~~~g~~mber,revised TIll
L ~cover letter "complete app,lr"cation"recei,ved date,added most
"current revision ofcover letter,added "renewa~"in
~~~-+-,fi,"n",'s"t"s"en""te"n"c",e--~I:Pag;:2-"-Ii Heading "Cha~ged dat~-~"n cover le~e~:changed eff~ct~~~date .
and Issue date ofthe permIt,changed "ChIef SIgnature I'
I---~~---'t +-,,,,e,,r,,s,,o!,-n
Page 3 ,_t
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e
3
1
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pagePeolf'mp'eitIlliI't ~:::~~,:,:;~:;~":CC""",ffi ,eO,,,m,.•••i
Pagel ..,Changed:Pemrit No.,"replaces Pennit No.
Revised:application No.,complete application date,I
I---,----+---b ennit number.is~ue dat~0.ill@tiondate --1
Page 2 Page 2 __+!!-~e-clContents RemovecL~Part11 'Se~tlOn ~____,
All pages AJI a es H"ading ,___Clran cd Permit No,to 08830T06
Pages 3-10 Pages 3-17 Body ofpermit Added the most current Title V language lor all
I---~--~t -------l affectccLsources -_._."..,",.-~
Pa es 11-19__-h;s 18-26 _Icieneral Condition~"J Added_most current language for General conditioll~.~_-.J
r------Insignifical]t Activities Under 15A NC'L<:"2'-'L"'0"i5,,,OC!3,l£8L,,~_~~m_~,!!.~~l!!L~i9nSonree n!'~!'rjJl!iOll __LSocur~".!1(IAPs_,Source oJTitle V Pollulanl __,I
IES-5 !Leachate managemenmstem I Yes _,,-----I Yes ----i
lES-7 lOne 2Q,900 ga]]on diesel storage tank tY~_,____I Y"'l '-l
[iES-8 hne IO,OOO~!!2!Lt!!!!£!lgedgasoline stot"~i!!!lL.YCL___J::Y~,---,
State ofNorth Carolina,
Department ofEnvironment,
and Natural Resources
Division ofAir Quality
AIR QUALITY PERMIT
Until such time as this pemlit expires or is modified or revoked,the below named Permittee is pClTIlitted to construct and
operate the emission source(s)and associated air pollution control device(s)specified herein,in accordance with the terms,
conditions,and limitations within this permit.This permit is issued under the provisions of Article 2IB ofChapter 143,
General Statutes of North Carolina as amended,and Title I SA North Carolina Administrative Codes (lSA NCAC),
Subchapters 20 and 2Q,and other applicable Laws.
Pursuant to Title lSA NCAC,Subchapter 2Q,the Permittee shall not construct,operate,or modify any emission souree(s)
or air pollution control dcvice(s)without having first submitted a complete Air Quality Permit Application to the pcnnitting
authority and received an Air Quality Pemlit,except as provided in this pennit.
Permittee:
Facility ID:
Facility Site Location:
City,County,State,Zip:
Mailing Address:
City,State,Zip:
Application Number:
Complete Application Date:
Primary SIC Code:
Division ofAir Quality,
Regional Office Address:
City of Greensboro -White ('Jtreet Landfill
4101086
2503 White Street
Greenshoro,Guilford County,North Carolina 27405
P.O.Box 3136
Greensboro,North Carolina,27402-3136
4101086.08A
April 22,2008
4953
Winston Salem Regional Office
585 Waughtown Street
Winston-Salem,North Carolina 27107
th day of August,2009
der Vaart,Ph.D.,P.E.,Chief,Air Permits Section
By Authority ofthe Environmental Management Commission
Page 2
Table Of Contents
SECTION 1:PERMITTED EMISSION SOURCE (S)AND ASSOCIATED
AIR POLLUTION CONTROL DEVICE (S)AND APPURTENANCES
SECTION 2:SPECIFIC LIMITATIONS AND CONDITIONS
2.1 -Emission Source(s)Specific Limitations and Conditions
(Including specific requirements,testing,monitoring,recordkeeping,and
reporting requirements)
SECTION 3:GENERAL PERMIT CONDITIONS
ATTACHMENT
List ofAcronyms
The Division ofAir Quality (DAQ),the United States Euvironmental Protection Agency (EPA),and citizens as defined under
the Federal CleanAir Act have the authority to enforce the terms,conditions,and limitations contained in the pemut unless
othcnvise specified.
Under Title l5A NCAC 2Q,the operation of emission somce(s)and associated air pollution control device(s)and
appurtenances listed in this pClmit is based on plans,specifications,operating parameters,and other infonnation as submitted in
the Air Quality PennitApplication.
SECTION 1-PERMITTED EMISSION SOURCES AND ASSOCIATED AIR POLLUTION
CONTROL DEVICES AND APPURTENANCES
The following table contains a summary ofall nermitted cmissiQjL§..QUI£.£.$and associated air nolJution control devices and appurtenances:-"-I
Emission Source II)No.Emission Source Descrintion Control Device ID No.Control Device Descriotion
ES~I Non-active (unlined)portion of GCCS~I One landfill gas collection and
NSPS,MACT landfill control system (ID No.GCCS~I)
CD~I including one candle stick-type
ES~2 Non~active (unlined)portion of flare (84 million Btu per hour heat
NSPS,MACT landfill input capacity,CD~1)-or-
CD-Treatment Landfill "as treatment system
ES~3 Portion oflandfill (lined)GCCS~2 One landfill gas collection and
NSPS,MACT control system (ID No.GCCS~2)
CD~3 including one candle stick-type
flare (49.2 million Btu per hom
heat input capacity,ID No.CD~3)
-or-
CD~Treatment JLandfill gas treatment system
ES-4 Horizontal grinder (diesel fue1-None I
fired 1 000 horseoower)-~.
None
--I
SECTION 2 -SPECIFIC LIMITATIONS AND CONDITIONS
2.1-Emission Source(s)and Control Devices(s)Specific Limitations and Conditions
The emission source(s)and associated air pollution control device(s)and appurtenances listed below are subject to the
following specific terms,conditions,and limitations,including the testing,monitoring,recordkeepillg,and reporting
requirements as specified herein:
A.Municipal solid waste landfill (ID Nos.ES-I,ES~2,and ES-3)with associated gas collection and control systems
(GCCS-I)inclndiug one candle stick-type flare (84 million Btu per hour heat input capacity,ID No.CD-I)and
one gas collection and control system (GCCS-2)inclnding one candle stick-type lIare (49.3 million Btu per hour
heat inpnt capacity,ID No.CD-3)
The following'table nrovides a summarY oflirnits and standards for the emission source(s)described above:
Re!!ulated·Pollutant Limits/Standards AnnlicableRe!!ulation ~
Nonmethane organic compounds Con1ToI systems !l5A NCAC 2D .0524
!NMOCl 40 CFR Part 60 SnbnartWWW
Sulfur dioxide 2.3 pounds per million Btn heat input 15A NCAC 2D .0516
--","--,"
Visible emissions 20 percent opacity 15A NCAC 2D .0521
.~-_.-
-Table continued on the ncxt page-
Paee 4
_The followim!tabl~_.Qlovides a summal oflimits and standards for the emission source(s)descrjped above:(continedl~egUlatedPollutant Limits/Standards _Annlicable Regulation __~
I Hazardous air pollutants (HAPs)Work practice standards &startup,15A NCAC 2D .1111 I
r=.shutdown,and malfunctIOn plan 40CFR Part 63,Snbpart AAA~·
Toxic air pollutants i Modeled limits 15A NCAC 2D .1100
1·State Enforceable Onlv.!
I
Facility wide toxics evaluatlO.n.15A NCAC 2Q .0705 I
_State Enforceable Only.(Last MACT,North Carolina~
1.15A NCAC 2D .0524:40 CFR Part 60,Snhpart WWW,New Sonrce Performance Standards
a.Emissions ofnonmethane organic componnds (NMOCs)from the landfill (ID Nos.ES-I,2,and 3)shall be
controlled by gas collection and control systems (ID Nos.CD-GCCSI and GCCS-2)that route the gas to open
flares (ID Nos.CD-I and CD-3)designed in accordance with 40 CFR Part 60,§60.18 and/or routes the
landfill gas to a gas treatment system (CD-Treatment)in accordance with 40 CFR Part 60,§60.752(b)(2)
(iii)(C).
Testing [15A NCAC 2D .0524,40 CFR §60.754]
b.When testing is required,the testing shall be performed in accordance with 40 CRF Part 60.752(b)(2)(iii)(A)
and General Condition JJ located in the General Conditions in Section3 ofthe pennit.If the results are above
the limits/standards given in Section 2.1 A.I.a.above,the Permittee shall be deemed in noncompliance with
the NMOC standard in40 CFR Part 60,Subpart WWW.
c.StandardsFof Ajr Emissions FrOID Munjcipal Solid Waste I andtiils (40 CPR Part 60)§60.752]
L The owner or operator ofa municipal solid waste landfill having a design capacity equal to or greater than
2.5 million megagrams by mass and 2.5 million cubic meters)with a calculated NMOC emission rate
equal to or greater than 50 megagrams per year,shall submit a gas collection and control system design
plan prepared by a professional engineer who is registered in the State ofNorth Carolina)within one year
of the annual report that shows that NMOC emissions will exceed 50 -Mg per year.
(A)The collection and control system design plan shall include any alternajjves to the operational
standards)test methods,procedures,compliance measures,monitoring,recordkeeping or reporting
provisions of §§60.753 through 60.758 proposed by the owner or operator.
(B)The collection and contTol system design plan shall either confonnwith specifications for active
collection systems in §60.759 or include a demonstration to the Administrator's satisfaction ofthe
sufficiency ofthe alternative provisions to §60.759.
(C)The Division ofAir Quality shall review the informationsubmitted in the gas collection and control
system design plan and either approve it,disapprove it,or request that additional information be
submitted.
(D)Ifthe calculated NMOC emission rate is equal to or greater than 50 megagrams per year,the
owner and operator shall install a collection and control system that captures the gas generated
within the landfill as required by paragraphs §60.752(b)(2)(ii)(A)or (B)and (b)(2)(iii)within 30
months after the first annual report in which the emission rate equals or exceeds 50 megagrams per
year,unless Tier 2 or Tier 3 sampling demonstrates that the emission rate is less than 50
megagrams per year,as specified in §60.757(c)(1)or 2.
(1)An active collection system shall:
(a)Collect gas from each area,cell,or group ofcells iu fhe landfill in which the initial solid
waste has been placed for a period of5 years or more ifactive;or 2 years or more if
closed or at final grade.
(b)Collect gas at a sufficient extraction rate and be designed to minimize off-site migration
ofsubsurface gas.
(c)Route all the collected gas to a control system that complies with the requirements in
eifher paragraph §60.752(h)(2)(iii)(A),(B)or (C).
(d)The control device shall he operated within fhe parameter ranges estahlished during the
initial or most recent performance test.The operating parameters to be monitored are
specified in §60.756.
d.OperatjoDal Standj1rds For CollectioIl and Control Systems [40 CPR Part 60,§60.753]
L Each owner or operator ofan MSW landfill with a gas collection and control systemused to comply
with the provisions of §60.752(h)(2)(ii)ofthis suhpart shall:
(A)Operate the collection system such that gas is collected from each area,cell,or group ofcells
in the MSW landfill in which solid waste has been in place for 5 years or more ifactive;or 2
years or more ifclosed or at final grade;
(B)Operate the collection system with negative pressure at each wellhead except under the
following conditions:
(1)A fire or increased well temperature.The owner or operator shall record instances when
positive pressure occurs in efforts to avoid a fire.These records shall be submittedwith
the annual reports as provided in §60.757(t)(1);
(2)Use ofa geomembrane or synthetic cover.The 0\\1l1er or operator shall develop
acceptable pressure limits in the design plan;
(3)A decommissioned well.A well may experience a static positive pressure after shut
down to accommodate for declining flows.All design changes shall he approved hy the
DAQ Regional Office;
(C)Operate each interior wellhead in the collection system with a landfill gas temperature less
than 55°C and with either a nitrogen level less than 20 percent or an oxygen level less than 5
percent.The O\vner or operator may establish a higher operating temperature,nitrogen,or
oxygen value at a particular well.A higher operating value demonstration shall show
supporting data that the elevated parameter does not cause fires or significantly inhibit
anaerobic decomposition by killing methanogens.
(1)The nitrogen level shall he determined using Method 3C,unless an alternative test
method is estahlishcd as allowed hy §60.752(h)(2)(i).
Page 6
(2)Unless an alternative test method is established as allowed by §60.7S2(b)(2)(i),the oxygen
shall be determined by an oxygen meter using Method 3A or 3C except that:
(a)The span shall be set so that the regulatory limit is between 20 and 50 percent ofthe
span;
(b)A data recorder is not reqnired;
(c)Only two calibration gases are required,a zero and span,and ambient air may be used
as the span;
(d)A calibration error clieck is not reqnired;
(e)Tlie allowable sample bias,zero drift,and calibration drift are ±I0 percent.
(D)Operate the collection system so that the methane concentration is less than 500 parts per million
above background at the surface ofthe landfilL To determine ifthis level is exceeded,the owner or
operator shall conduct surface testing around the perimeter ofthe collection area and along a pattern
that lT3verses the landfill at 30 meter intervals and where visual observations indicate elevated
concentrations oflandfill gas,such as distressed vegetation and cracks or seeps in the cover.The
owner or operator may establish an alternative traversing pattern that ensures equivalent coverage.A
surface monitoring design plan shall be developed that includes a topographical map with the
monitoring route and the rationale for any site-specific deviations from the 30 meter intervals.Areas
with steep slopes or other dangerous areas may be excluded from the surface testing.
(E)Operate the system such that all collected gases are vented to a control system designed and operated
in compliance with §60.752(b)(2)(iii).In fhe event the collection or control system is inoperable,fhe
gas mover system shall be shut down and all valves in the col1ection and control system contributing
to venting ofthe gas to the atmosphere shall be closed within 1 hour; and
(F).Operate the control or treatment system at all times when the collected gas is routed to the system.
(G)Ifmonitoring demonstrates that the operational requirements in pmagraphs §60.753(b),(c),or (d)are
not met,corrective action shall be taken as specified in §60.755(a)(3)tlirougli (5)or §60.755(c)of
this subpart.Ifcorrective actions are taken as specified in §60.755,the monitored exceedance is not a
violation ofthe operational requirements in this section.
e,Compliance Provisions [40 CFR Pa1160,§60,755j
1.For the purpose ofdemonstrating whether the gas collection system flow rate is sufficient to
determine compliance with §60.752(b)(2)(ii)(A)(3),the owner or operator shall measure gange
pressure in the gas collection header at each individual well,monthly.Ifa positive pressure exists,
action shall be initiated to correct the exceedance within 5 calendar days,except for the three
conditions allowed under §60.753(b).Ifnegative pressure caunot be achieved without excess air
infiltration within 15 calendardays ofthe first measurement,the gas collection system shall be
expanded to correct the exceedance within 120 days ofthe initial measurement ofpositive pressure.
Any attempted corrective measure shall not cause exceedances ofother operational or perfonnance
standards.An alternative timel1ne for correcting the exceedance shall be submitted to the DAQ
Regional Office for approval.
n.Owners or operators are not reqnired to expand the system as required in paragraph §60.755(a)(3)
during the first 180 days after gas collection system startup.
iii.For the purpose ofidentifying whether excess air infiltTation into the landfill is occuning,the owner
or operator shall monitor each well monthly for temperature and nitrogen or oxygen as provided in
§60.753(c).Ifa well exceeds one ofthese operating parameters,action shall be initiated to conect the
exceedance within 5 calendar days.If correction ofthe exceedance cannot be achieved within 15
calendar days of the first measurement,the gas collection system shall be expanded to conect the
exceedance within 120 days ofthe initial exceedance.Any attempted corrective measure shall not
cause exceedances ofother operational or performance standards.An alternative timeline for
conecting the exceedance shall be submitted to tbe DAQ Regional Office for approval.
IV.An owner or operator seeking to demonstrate compliance with §60.752(b)(2)(ii)(A)(4)through the
usc ofa collection system not conforming to the specifications provided in §60.759 shall provide
information satisfactory to the DAQ as specified in §60.752(b)(2)(i)(C)demonsttating that of1'site
migration is being controlled.
v.For purvoses ofcompliance with §60.753(a),each owner or operator ofa controlled landfill shall
place each well or design component as specified in the approved design plan as provided in
§60.752(b)(2)(i).Each well shall be installed no later than 60 days after the date on which the initial
solid waste has been in place for a period of5 years or more jfactive;or 2 years or more ifclosed or
at flnal grade.
vi.The following procedures shall be used for compliance with the surface methane operational standard
as provided in §60.753(d).
(A)After installation ofthe col1ection systeml the owneror operator shall monitor surface
concentrations ofmethane along the entire perimeter ofthe collection area and along a pattern
that traverses the landfill at 30 meter intervals (or a site-specific established spacing)for each
collection area on a quarterly basis using an mganic vapor analyzer,flame ionization detector,
or other portable monitor meeting the specifications provided in paragraph (0)ofthis section.
(B)The background concentration shall be determined by moving the probe inlet upwind and
downwind outside the boundary ofthe landfill at a distance ofat least 30 meters fi'om the
perimeter wells.
(C)Surface emission monitoring shall be performed in accordance with section 4.3.1 ofMethod
21 of appendix A of this part,except that the probe inlet shall he placed within 5 to 10
centimeters orthe ground.Monitoring shall be performed during typical meteorological
conditions.
(D)Any reading of500 parts per million or more above background at any location shall be
recorded as a monitored exceedance and the actions specified in paragraphs §60.755(c)(4)(i)
through (v)shall be taken.As long as the specified actions are taken,the exceedance is not a
violation ofthe operational requirements of§60.753(d).
(1)The location ofeach monitored exceedance shall be marked and the location recorded.
(2)Cover maintenance or adjustments to the vacuum ofthe adjacent wells to increase the gas
collection in the vicinity ofeach exceedance shall be made and the ]oc31ion shall be re-
monitored within 10 calendar days ofdetecting the exceedance.
(3)If the re-monitoring ofthe location shows a second exceedance,additional corrective
action shall be taken and the location shall be monitored again within 10 days ofthe
second exceedance.Ifthe re-monitoring shows a third exceedance for the same location,
the action specified in paragraph §60.755(c)(4)(v)shan be taken,and no further
monitoring ofthat location is required until the action specified in paragraph
§60.755(c)(4)(v)has been taken.
Page 8
(4)Any location that initially showed an exceedance but has a methane concentration less
than 500 ppm methane above background at the lO-day re-monitoring specified in
paragraph §60.755 (c)(4)(ii)or (iii)shall be re-monitored 1 month from the initial
exceedance.Ifthe I-month remonitoring shows a concentration less than 500 parts per
million above background,no further monitoring ofthat location is required until the
next quarterly monitoring period.If the I-month remonitoring shows an exceedance,the
actions specified in paragraph (c)(4)(iii)or (v)shall be taken.
(5)For any location where monitored methane concentration equals or exceeds 500 parts per
million above background three times within a quarterly period,a new well or other
collection device shall be installed within 120 calendar days ofthe initial exceedance.An
altelnative remedy to the exceedance,such as upgrading the blower,header pipes or
control device,and a corresponding timeline for installation shall be submitted to the
DAQ for approval.
(E)The owner or operator shall implement a program to monitor for cover integrity and implement
cover repairs as necessmy on a monthly basis.
(F)Each owner or operator seeking to comply with the provisions in paragraph §60.755(c)shall
comply with the following instrumentation specifications and procedures for surface emission
monitoring devices:
(1)The portable analyzer shall meet the instrument specifications provided in section 3 of
Method 21 ofappendix A ofthis part,except that "methane"shall replace all references to
VOc:.
(2)The calibration gas shall be methane,diluted to a nominal concentration of500 palts per
million in air.
(3)To meet the perf01mance evaluation requirements in section 3.1.3 ofMethod 21 ofappendix
A ofthis part,the instrnment evalnation procedures ofsection 4.4 ofMethod 21 ofappendix
A ofthis part shall be nsed.
(4)·Tbe calibration procedures provided in section 4.2 ofMefhod 21 ofappendix A ofthis part
shall be followed immediately before conullencing a surface monitoring survey.
(G)The provIsions of this snbpart apply at ail times,except during periods ofstart-up,shntdown,or
malfunction,provided thatthe.duration ofstart-up;·shutdoWIl;·or malfunction shall not exceed 5
days for collection systems and shall not exceed 1 hour for treatment or control devices.
f.Monitoring [15A NCAC 2Q .0508(f),40 CFR §60.756]
i.Each owner or operator seeking to comply wifh §60.752(b)(2)(ii)(A)for an active gas collection
system shall install a sampling port and a thermometer,other temperature measuring device)or an
access port for temperature measurements at each wellhead and:
(A)Measure tbe gange pressure in the gas collection header on a monthly basis as provided in 40
CFR §60.755(a)(3);
(B)Monitor nitrogen or oxygen concentration in the landfill gas on a monthly basis as provided in
40 CFR §60.755(a)(5);
(C)Monitor temperature of the landfill gas on a monthly basis as provided in §60.755(a)(5);and
(D)Monitor surface concentrations ofmethane along the entire perimeter of the collection area (or
site-specific established spacing)for each collection area on a quarterly basis.
Page 9
II.The owner or operator shall calibrate,maintain,and operate according to the manufacture's
recommendations the following equipment when using an open flare to comply with this Subpart:
(A)A heat sensing device,such as an ultraviolet beam sensor or thermocouple,at the pilot light or
the flame itselfto indicate the continuous presence ofa flame.
(B)A device that records flow to or bypass ofthe flare.The owner or operator shall either:
(1)Install,calibrate,and maintain a gas flow rate measuring device that shall record the flow to
the control device at least every 15 minutes;or
(2)Secure the bypass line valve in the closed position with a car-seal or a lock-and-key type
configuration.A visuahnspection ofthe seal or closure mechanism shall be perfonned at
least once every month to ensure that the valve is maintained in the closed position and that
the gas flow is not diverted through the bypass line.
111.Each owner or operator seeking to install a collection system that does not meet the specifications in
40 CFR §60.759,or seeking to momtor alternative parameters to those required hy 40 CFR §60.753
through §60.756,shall provide information satisfactory to the EPA as provided in
§60.752(b)(2)(i)(B)and (C)describing the design and operation of the collection system,the
operating parameters that would indiCate proper performance,and appropriate monitoring
procedures.
g.Recordkeeping [40 CFR Part 60,§60.758]
r.Except as provided in §60.752(b)(2)(i)(B).each owner or operator ofan MSW landfill subject to the
provisions of §60.752(b)shall kcep for at least 5 years up-to-date,readily accessihle,on-site records
oflbe design capacity report which triggered §60.752(b),the current amonnt ofsolid waste in-place,
and the year-by-year waste acceptance rate.Off-site records may be maintained ifthey are retrievable
within 4 hours.Either paper copy or electronic formats are acceptable.
n.Except as provided in §60.752(b)(2)(i)(B),each owner or operator ofa controlled landfill shall keep
up~to-date,readily accessible records for the life ofthe control equipment ofthe data listed below in
this section as measured during the initial performance test or compliance determination.Records of
subsequent tests or monitoring shall be maintained for a minimum of 5 years.Records of the control
device vendor specifications shall be maintained until removal.
(A)Where ail m\tner or operator subject to the provisions ofthis subpart seeks to demonstrate
compliance with §60.752(b)(2)(ii):
(1)The maximum expected gas generation flow rate as calculatcd in §60.755(a)(I).The
owner or operator may use another method to detennine the maximum gas generation
flow rate,if the method has been approved by the DAQ.
(2)The density of wells,horizontal collectors,surface collectors,or other gas extraction
devices determined using the procedures specified in §60.759(a)(l).
(B)Where an owner or operator subject to the provisions ofthis subpart seeks to demonstrate
compliance with §60.752(b)(2)(iii)(A)throngh use ofan open flare,the flare type (i.e.,steam"
assisted,air-assisted,or nonassisted),all visible errrission readings,heat content determination,
flow rate or bypass flow rate measurements,and exit velocity determinations made during the
performance test as specified in §60.18;continuous records ofthe flare pilot flame or flare flame
monitoring and records ofall periods ofoperations during which the pilot flame ofthe flare
flame is absent.
Page 10
(C)Except as provided in §60.752(b)(2)(i)(B),eacb owner or operator ofa controlled landfill
subject to the provisions ofthis subpart shall keep for 5 years up-ta-date,readily accessible
continuous records ofthe equipment operating parameters specified to be monitored in
§60.756 as well as up-ta-date,readily accessible records for periods ofoperation during which
the parameter boundaries established during the most recent performance test are exceeded.
(D)Each owner or operator subject to the provisions ofthi5 subpart shall keep up-ta-date,readily
accessible continuous records of the indication offlow to the control device or the indication
ofbypass flow or records ofmonthly inspections ofcar-seals or lock-and-key configurations
used to seal bypass lines,specified uuder §60.756.
,(E)Each owner or operator seeking to comply with the provisions ofthis subpart by use ofan
open flare shall keep up-to-date,readily accessible continuous records of the flame or flare
pilot Dame monitoring specified under §60.756(c),and up-ta-date,readily accessible records
ofall periods ofoperation in which the flame or flare pilot flame is absent.
(F)Except as provided in §60.752(b)(2)(i)(B),eacli owner or operator snbject to the provisions of
this subpart shall keep for the life of the collection system an up-ta-date,readily accessible plot
map showing each existing and planned collector in the system and providing a unique
identification location label for each collector.
(G)Each owner or operator subject to l11C provisions ofthis subpart shall keep up~to-date,readily
accessible records ofthe installation date and location ofall newly installed collectors as
specified under §60.755(b).
(H)Each owner or operator subject to the provisions ofthis subpart shall keep readily accessible
documelltationofthe nature,date of deposition,amount,and location of asbestos-containing
or nondegradable waste excluded hom collection as provided in §60.759(a)(3)(i)as well as
any nonproductive areas excluded from collection as provided in §60.759(a)(3)(ii).
(I)Except as provided in §60.752(b)(2)(i)(B),eacli owner or operator subject to tlie provisions of
this subpart shall keep for at least 5 years up-to-date,readily accessible records ofall
collection and control system exceedances ofthe operational standards in §60.753,the reading
in the subsequent month whether or not the second reading is an exceedance,and the location
ofeach exceedance.
li.Sllerifications of Actjye Collectjon Systems [40 CFR Part 60,§60.759]
L Each owner or operator seeking to comply witli §60.752(b)(2)(i)sliall site active collection wells,
horizontal collectors,surface collectors,or other extraction devices at a sufficient density throughout
all gas producing areas using the following procedures unless alternative procedures have been
approved by the Division ofAir Qnality as provided in §60.752(b)(2)(i)(C)and (D).
.(A)l'he collection devices within the interior and along the perimeter areas shall be certified to
achieve comprehensive control of surface gas emissions by a professional engineer,who is
registeredin the State ofNorth Carolina.The following issues shall be addressed in the design
plan:depths ofrefuse,refuse gas generatiO!l rates and now characteristics,cover properties,
gas system expandabihty,leachate and condensate management)accessibility,compatibility
with filling operations,integration with closure end use,air intrusion control,corrosion
resistance,fiU settlement,and resistance to the refuse decomposition heat.
(B)Tlie sufficient density ofgas collection devices determined above in this section sliall address
landfill gas migration issues and augmentation ofthe collection system through the use of
active or passive systems at the landfill perimeter or exterior.
Page 11
(C)The placement ofgas collection devices determined above in this section shall control all gas
producing areas,except as provided below:
(1)Any segregated area of asbestos or nondegradable material may be excluded from
collection ifdocumented as provided under §60.758(d).The documentation shall
provide the nature,date ofdeposition,location and amount ofasbestos or
nondegradable material deposited in the area.Ifany area ofthe landfill qualifies for
exclusion under §60.758(d),the Permittee shall provide tlie stipulated data as a request
for approval to the DAQ Regional Office.
(2)Any nonproductive area of the landfill may be excluded from control,provided that the
total ofan excluded areas can be shown to contribute less than 1 percent ofthe total
amount ofNMOC emissions from the landfilL The amount location,and age of the
material shall be doculncnted and provided to the Division ofAir Quality upon request.
A separate NMOC emissions estimate shall be made for each section proposed for
exclusion,and the sum ofall such sections shall be compared to the NIvfOC emissions
estimate for the entire-landfilL If any area of the landfill qualifies for exclusion under
§60.759(3)(ii),the Permittee shall provide the stipulated data by letter as a request for
approval to the DAQ Regional Office.
1.Site Specific Heqnjrements
A.Operate the collection system with an acc.eptable pressure limit of5 inches ofwater column at
each wellhead in areas that have a geomembrane cover in accordance with 40 CPR
60.753(b)(2).
B.The collection oflandfill gas from the leachate system using leachate risers and leachate sump
extraction to contTol odor and surface emissions that are tied into the gas collec.tion and control
system,are exempt from the pressure,temperatm:e,nitJ:ogen,and/or oxygen exceedance limits
ofSubpartWWW as long as they are not collecting gas from an area,cell,Or group ofcells in
which the initial solid waste has been in place for a period oftlve years or more (ifactive),or
two years or more (ifclosed or at final grade).
Ifthe collection oflandfill gas from the leachate system using leachate risers and leachate
sump extraction is from an area or cell in which the initial solid waste has been in place for a
period offive years or more (ifactive),or two years or more (ifclosed or at final grade),the
temperature,pressure,nitrogen and/or oxygen shall not exceed the limits of Subpart W-WV\T,
except the oxygen limit shall be less than or equal to 20 percent,as long as subsurtace
oxidation and the killing of the methanogens does not occur.
C.The Vvhite Street Landfill is allowed to use an on-site multi-gas analyzer,in lieu ofa
laboratory method,for detelmining the oxygen content ofthe landfill gas at interior wellheads
and monitoring points,when applicable.The site shall use a portable meter,such as a GEM-
500,GEtvI-2000,or equivalent,calibrated to the manufacturer's specifications in accordance
with a prior EPA approval letter to Mr.Jim Walsh ofSCS Engineers,dated May 14,2001.
D.The landfill is allowed to exclude dangerous areas with slopes steeper than 4:1 from surface
ell'issions monitoring requirements in accordance with 40 CFR §60.653(d).'Visual
observations should be made to locate areas that indicate elevated concentrations ofmethane,
such as distressed vegetation,cracks or seeps in the covers.
E.40 CFR §60.752(b)(2)(i)(B)allows for the exclusion ofsorface monitoring in "dangerous
areas"ofthe landfill site.This facility is allowed to exclude the monthly readings (pressure,
nitrogen or oxygen content,and temperature)at wellheads on new or existing vertical gas
extraction wells that have been niised and placed in active areas as long as the wen heads can
not be safely reached by the tec1mician.Ifthe facility can notbring the waste height up to the
new grade and re-attach the wen within a reasonable time (four months),then modifications to
the lateral/wellhead shall be cut back down and re-attached to begin the required monitoring.
F.White Stteet landfill is allowed to usc EPA Method 3C in place ofEPA Method 18 and ASTM
1946 to determine landfill gas components for calculating net heating valne under 40 CFR
60.18(c)(3).
~Cl 11tH VOOJV ~VU
Page 12
J.Well Closure [40 CFR Part 60,§60
Ifany gas collection well qnalifies for exclusion uuder §60.753(b)(3)as a decommissioned well,the
Pem1ittee shall provide adequate documentation and data to justify well closure,This information shall be
provided by letter to the DAQ Regional Office as a request for approval.
k.Reporting [40 CFR Part 60,§60.757]
(A)Each owner or operator seeking to comply with §60.752(b)(2)using an active collection system
designed in accordance with §60.752(b)(2)(ii)sball submit to the Division ofAir Qnality anoual
reports ofthe recorded information listed below in this section.
(I)Value and length oftime for exceedance ofapplicable parameters monitored under 40 CFR
§60.756(a),(b),(c),and (d).
(2)Description and duration ofall periods when the gas stream is diverted from the control
device through a bypass line or the indication ofbypass How as specified in 40 CPR
§60.756.
(3)Description and duration ofall periods when the control device was not operating for a
period exceeding one hour and length oftime t~1e control device was not operating.
(4)All periods when the collection system was not operating in excess of 5 days.
(5)The location ofeach exceedance ofthe 500 parts per million methane concentration and the
concentration recorded at each location for which an exceedance was recorded in the
previous month.
(6)The date ofinstallation and the location of each well or collection system expansion added
in accordance with 40 CFR §60.755(a)(3),(b),and (c)(4).
(7)Summary ofall DAQ approved well closures that have been decommissioned in accordance
with wells §60.753(b)(3).
(8)Summary ofall DAQ approved nonprodnctive areas ofthe landfill in accordance with
§60.759(a)(3)(ii).
(E)The initial anoual report shall be submitted within 180 days ofthe installation and start-up ofthe
collection and control system,and shall include the initial performance test report required under 40
CFR §60.8.
(C)The Pennittee shall submit a summary report ofmonitoring and recordkeeping activities by
January 30 ofeach calendar year for the preceding six-month period between July and December
and July 30 of each calendar year for the preceding six-month period between January and June.
All instances ofdeviations from the requirements ofthis permit must be clearly identified.
2.15A NCAC 2D .0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a.Emissions of sulfur dioxide from flares (CD-I and CD-3)shall not exceed 2.3 pounds per million Btu heat
input.Sulfur dioxide fonned by the combustion of sulfur in fuels,wastes,ores,and other substances shall be
included when detemIining compliance with this standard.
Testing [15A NCAC 2D .0501(e)(4)]
b.If testing is required,the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(4)and
General Condition JJ located in Section 3 ofthe PemIit.If the results ofthis test are above the limit given in
Section 2.1 A.2.a.above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516.
MonitoringlReconlkeepinglReporting [15A NCAC 2Q.0508 (1)]
c.No monitoring,recordkeeping,or reporting is required for sulfur dioxide emissions from the firing of landfill
gas in any flare (CD-lor CD-3).
Page 13
3.15A NCAC 2D .0521:CONTROL OF VISIBLE EMISSIONS
a.Visihle emissions from flares (CD-lor CD-3)shall not be more than 20 percent opacity each when averaged
over a six-minute period.However,six-minute averaging periods may exceed 20 percent not more than once
in any hour and not more than four times in any 24-hour period.In no event shall the six-minute average
exceed 87 percent opacity.[15A NCAC 2D .0521 (d)]
Testing [15A NCAC 2D .0501(c)(8)]
b.Ifemissions testing is required,the testing shall be performed in accordance with 15A NCAC 2D 0501(c)(8)
and General Condition JJ located in Section 3 ofthe Pemnt.Ifthe results ofthis test are above the limit given
in Section 2.1 A.3.a.above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521.
MonitoringlRecordkl'epinglReporting [lSA NCAC 2Q .0508(!)]
c.No monitoring,recordkeeping,or reporting is required for visible emissions from the firing of landfill gas in
the candle stick-type flares (CD-lor CD-3).
4.15A NCAC 2D .1111,40 CFR Part 63,Subpart AAAA:National Emission Standards for Hazardous Air
Pollntants,Municipal Solid Waste Landlllls
a.The landfill (ID Nos.ES-I,ES-2,and ES-3)sball comply with all requirements of 15A NCAC 2D .1111
"Maximum Achievable Control Technology"and 40 CFR Part 63,Subpart AAAA "National Emission
Standards for Hazardous Air Pollutaut,Mnnicipal Solid Waste Landfills"[40 CFR.§63.1935J
Monitoring [40 CFR Part 63,§63.1955 and §63.1960]
b.Compliance.with this Subpart (AAAA)is determined in accordance with the New Source PerfODnance
Subpart WWW,including performance testing,monitoring ofthe collection system,continuous parameter
monitor,and other credible evidence.Inaddition,continuous parameter monitoring data,collected under 40
CFR §60.756(c)(1)and (d)ofSubpart WWW,are used to demonstrate compliance with the operating
conditions for control systems.
The Permittee must develop and implement a "{ritten Start-UplShutdownfMalfunction (SSM)plan according
to the provision in 40 CFR 63.6(e)(3).A copy ofthe SSM shall be maintained on site.
Deviation means any instance in which an affected source subject to this subpart,or an owner or operator of
such a source:
l.fails to meet any requirement or obligation established by this subpart,including,but not limited to,any
emissions limitation (including any operating limit)or work practice standard;
ii.fails to meet any term or condition that is adopted to implement an applicable requirement in this subpart
and that is included in the operatingpermitfor any affected source required to obtain such a permit;
111.fails to meet any emission limitation,(including any operating limit),or work practice standard in this
subpart during SSM,regardless ofwhether-or not such failure is penIlltted by this subpart;or
IV.fails to write,develop,implement,or maintain a copy ofthe SS'M plan.
Ifa deviation occurs,the Permitteehas failed to meet the conh'ol device operating conditions described in this
subpart and have deviated from the requirements ofthis subpart
RecordkeepinglReporting Requirements [40 CFR Part 63,§63.l980]
c.Keep records and reports as specified in the general provisions of40 CFRPart 60,and in Subpart WWW,
except the annnal report described in 40 CFR §60.757(!)shall be submitted every 6 months.
Ifactions taken during a startup,shutdown,and malfunction plan are consistent with the procedures in the
startup,shutdown,and malfunction plan,this information shall be included in a semi-annual startup,shutdown,
and malfunction plan report.Any time an action taken during a startup,shutdown and malfunction plan is not
consistent with the startup,shutdown and malfunction plan,the source shall report actions taken within 2
working days after connnencing such action,followed by a letter 7 days after the event
J.....u ..~UUU-.1V ..\'"
Pa~e 14
B.Diesel fired horizontal grinder (1,000 HP 1D No.ES-4)
The follo\\'ing table nrovides a summarv oflimits and standards for the emission source(s)described above:Re~nlated PolI~tant ~Li!nit;jst';;d~~dS _JApplicahle Regulation ~_=-=_J
PM E ~4.10 x P 007 I 15A NCA,~<::~2,"D",-".0",,5,",I",,5 -j
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516~__.c._.__~-'-__~_~__
Visible emissions 20 percent opacity 15A NCAC 2D .0521
1.15A NCAC 2D .0515:PARTICULATES FROM MISCELLAt'lEOUS INDUSTRIAL PROCESSES
a.Emissions ofparticulate matter from this source shallllot exceed an allowable emission rate as calculated by
the following equation:[15A NCAC 2D .0515(a)]
Where E =,allowable emission rate in pounds per hour
P =:process weight in tons per hour
Liquid and gaseous fuels and combustion air-are nat considered as part ofthe process weight.
Thsling [15A NCAC 2D .0501 (c)(3)]
b.Ifemissions testing is required,the testing shall be perfOlmed in accordance with General Condition J1 Ifthe
results ofthis test are above the limit given in Sectiorr2:I B;1.a.above,the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0515~
MOnitoringlRecordkeeping [15A NCAC 2Q .0508(1)]
c.The Pemlittee shall maintain production records whiCh specify the types ofmaterials processed and shall make
these records available toa DAQ authorized represe~tative upon'request.The Permittee shall be deemed in
noncompliance with l5A NCAC2D .0515 ifthe production records are not maintained or the types of
materials and finishes are not monitored.
Reporting [15A NCAC 2Q .0508(f)]
d.The Permittee shall submit a sUlTImaIY report ofmonitoring and recordkeeping activities postmarked on or
before January 30 ofeach calendar year for the preceding six-month period between July and December and
July 30 ofeach calendar year for the preceding six-month period between January and June.All instances of
deviations from the requirements ofthis permit must be clearly identified.
2.15A NCAC 2D .0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a.Ernissions ofsulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input.Sulfur
dioxide formed by the combustion ofsulfur infuels,wastes,ores,arid other substances shall be included when
determining compliance with this standard.[15A NCAC 2D :0516]
Testing [15A NCAC 2D .0501(c)(4)J
b.Ifemissions testing is required,the testing shall he perfonned in accordance with 15A NCAC 2D .0501 (c)(4)
and General Condition JJ found in Section3.Ifthe results ofthis test are above the limit given in Section 2.1
B.2.a.above,the Pennittee shall he deemed in noncompliance with 15A NCAC 2D .0516.
MonitoringlRcmrdkeeping [15A NCAC2Q .0508(f)]
c.No monitoring or recordkeeping is required for sulfur dioxide emissions from grinder (ES-4).
3.15A NCAC 2D .0521:CONTROL OF VISIBLE EMISSIONS
3.Visible emissions from grinder (ES-4)shall not be morc than 20 percent opacity when averaged over a six-
minute period.However,six-minute averaging periods may exceed 20 percent not more than once in any hour
andnot more than four times in any 24~hour period.In no event shall the six~minute average exceed 87
percent opacity.[15A NCAC 02D .0521 (d)]
Iesting [15A NCAC 2D0501(c)(8)]
b.[femissions testing is required,the testing shall be perfonned in accordance with l5A NCAC 02D .2601 and
General Condition n.If the results of this test are above the limit given in Section 2.1 B.3.a.(ES-4)above,
the Permittee shall be deemed in noncompliance with [5A NCAC 02D .0521.
Monitoring [15A NCAC 2Q .0508(1)]
c.To assure compliance,once a day the PC1111ittee shaH observe the emission points ofthis source for any visible
emissions above normal.The daily observation mLlst be illude for each day ofthe calendar year period to
ensure compliance with this requirement.The Pennittee shall be allowed three (3)days ofabsent observations
per semi-annual period.Ifvisible emissions from this source are observed to be above nonnal,the Permittee
shall either:
1.take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,or
11.demonstrate that the percent opacity from the emission poi11t5 ofthe emission source in accordance with
15A NCAC 02D .2601 (Method 9)for 12 minutes is below the limit given in Section 2.1 B.3.a.above.
Ifthe above-nonnal emissions are not corrected per (1)above or ifthe demonstration in (ii)above cannot be
made,the Pennittee shall be deeined to be in noncompliance with l5A NCAC 02D .0521.
Recordkeepjng [15A NCAC 2Q .0508(1)]
d.The results ofthe monitoring shall be maintained in a logbook (written or electronic format)on-site and made
available to an authorized representative upon request.The logbook shaH record the following:
1.the date and time ofeach recorded action;
11.the results ofeach observation and/o[test noting those sources with emissions that were observed to be in
noncompliance along with any cortective actions taken to reduce visible emissions;and
111.the results ofany corrective actions perfoITaed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained
Reporting [15A NCAC 02Q .0508(1)]
e.The Pennittee shall submit a summary report ofthe observations postmarked on or before January 30 ofeach
calendar year for the preceding six-month period between July and December and July 30 ofeach calendar
year for the preceding six-month period between January and June.All instances ofdeviations from the
requirements ofthis permit mustbe clearly identified;
-".....HU.UUUJU -"uV
STATE-ONLY REQUIREMENT
4.15A NCAC 2Q .0705 "Existing Facilities And SIC Calls",
15A NCAC 2D .1100 "Control OfToxic Air Pollntants"
Toxic Air Pollntant Emissions Limitation And Reqnirements -Pursuant to 15A NCAC 2Q .0705 and in
accordance with the approved application for an air toxic compliance demonstration,the following pennit limits
shaUnot be exceeded in accordance with 15A NCAC 2D .1100:
Emission Sources Toxic Air Pollutants Emission Limits -
ES-l,ES-2,and ES-3 Acrvlonitrile 370 Ibs ner vear
(Municipal solid waste landfill)Benzene 212 Ibs Der vear
~lh::Qrogen sulfide -3.841bs Der day
L Methvl mercaptan 0.015 lbs per hour -
Vinvl chloride ~sperYcar
STAT~~-ONLY REQUIREMENT
5.15A NCAC 2Q .0705:Existing Facilities and SIC Calls
15A NCAC 2Q .0711 "Emission Rates Reqniring A Permit"
TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT -Pursuant to 15A NCAC 2Q .0705.
the White Street Landfill (ID Nos.ES-I,2 and 3),shall be operated and maintained in such a manner that emissions of
any listed toxic air pollutants from the facility,including fugitive emissions,will not exceed t~e "Emission Rates
Requiring A Permit"specified in 15A NCAC 2Q .0711.In accordance with the approved application,the Permittee
shall maintain records ofoperational information demonstrati.ng that the toxic air pollutant emissions do not exceed
the ernissiouratesas lIsted below:Iii the i5fthesethi'esh61ds
15A NCAC 2D.1100 shall be demonstrated.
a.As ofSeptember 26,2005,emissions oftoxie air pollutants have been demonstrated on a facility-wide basis
(excluding those sources exempt under 15A NCAC 2Q .0702 "Exemptions")that each ofthe toxic air
pollutants (TAPs)emitted from all sources at the facility are either below its respective toxic permit emission
rates (TPER)listed in 15A NCAC 2Q .0711 -"Emission Rates Requiring a Permit"or the TAPs are in
compliance with 15A NCAC 2D .1100 llControl ofToxic Air Pollutants!!as described elsewhere in this
pennit.
b.The facility shall be operated and maintained in such a manner that any nc\v,existing or increased actual
emissions ofany TAP listed in 15A NCAC 2Q .0711 or in this permit from all sources at the facility
(excluding those sources exempt nnder 151.NCAC 2Q .0702 "Exemptions"),including fugitive emissions and
emission sources not otherwise required"to have a pennit,will not exceed it"respective TPER listed in 15A
NCAC 2Q .0711 without first obtaining an air pertnit to construct or operate.
c.PRIOR to exceeding any ofthe TPERs listed in 15A NCAC 2Q .0711,the Permittee shall be responsible f(lr
obtaining an air pemllt to emit TAPs and for demonstratitlg compliance with the requirements of 15A NCAC
2D .1100 "Control ofToxic Air Pollutants".
d.The Permittee shall maintain at the facility records ofoperational information sufficient for demonstrating to
the Division ofAir Qnality staffthat actnal TAPs are less than the rate listed in 15A NCAC 2Q .0711.
c.The TPER table listed below is provided is 0 assist the Permittee in detennining when an air pennit is required.
.I.11;;1 11111 UOO,JV J.VU
Page 17
Threshold
Ilbslhr)
.l t:l HUl UOOJU.l UU
Page 18
SECTION 3 -GENERAL CONDITIONS (version 2.22.1)
This section describes terms and conditions applicable to this Title V facility.
A.Gem'raJ Proyisjons [NCGS 143-215 and 15A NCAC 2Q .0508(i)(16)]
1.Terms not otherwise detined in this pennit shall have the meaning assigned to such terms as defined in 15A NCAC 2D
and 2Q.
2.The tenns,conditions,requirements,limitations,and restrictions set forth in this permit are binding and enforceable
pursuant to NCGS 143-215.114A and 143-215.114B,including assessment ofcivil and/or criminal penalties.Any
unauthorized deviation from the conditions ofthis permit may constitute grounds for revocation and/or enforcement
action by the DAQ.
3.This pem1it is not a waiver oforapproval ofany otller Depmtment permits that may be required for other aspects of
the facility which are not addressed in this permit.
4.This pem1it does not relieve the Pennittee from liability for hannor injury to human health or welfare,animal or plant
life,or property caused by the construction or operation oHhis permitted t1cility,or from penalties therefore,nor does
it anow thePennittee to cause pollution in contravention ofstate laws orrules"Lmless specifically authorized by an
order from the North Carolina Environmental Management Commission.
S.Except as identified as state-only requirements in this pem1it,all telTIlS and conditions contained herein shall be
enforceable bythe DAQ,the EPA,and citizens ofthe United States as defined in the Federal Clean Air Act.
6.Any stationary source ofair pollution shall not be operated,maintained,or modified without the appropriate and valid
permits issued by the DAQ,LIDless the source is exempted by rule.The DAQ may issue a permit only after it receives
reasonable assurance that the installationwill not cause air pollution in violation ofany ofthe applicable requirements.
A permitted installation may only be operated,maintained,constructed,expanded,or modified in a manner that is
consistent with the terms ofthis permit.
13..P.ermit Availability [ISA NCAC 2Q0507(k)and .0508(i)(9)(B)]
The Permittee shaH have available at the facility a copyofthis permit and shall retain forthe duration ofthe pennit tenn
dneCbii1plete copy-of the'application'-a:iidahy iiiforroofioifsllbmittcifHi support onhe ap~lliC8.tlonpacka:ge.'erhe perrnit
application ~~hal1 be ma'de available to an authorized representative ofDepartment ofEnviron:..tl1ent and Natural Resources
uponrequest.
C.Seyerability C1anse [15A NCAC 2Q .0508(i)(2)]
In the event ofan administrative challenge to a fmal and binding permit in which a condition is held to be invalid,the
provisions in this permitare severable so that all requirements contained in the penTut,except those held t~)be invalid,shall
remain valid and must be complied with.
D.Submissions [15A NCAC 2Q .0507(e)and 2Q .0508(i)(16)]
Except as otherwise specified herein,two copies ofall documents,reports,test data,monitoring data,notifications,request
for renewal,and any other infonnation required by this pemnt shall be submitted to the appropriate Regional Office.Refer
to the Regional Office address on the coverpage ofthis permit.For continuous emis,sions monitoring systems (CE~:IS)
repOlts,continuous opacity monitoring systems (CaMS)reports,quality assurance (QAJlquality control (QC)reports,acid
rain CEM certification reports,and NOx budget CErvI certification reports,one copy shaH be sent to the appropriate
Regional Office and one copy shall be sent to:
Supervisor,Stmionary Source Compliance
NOlth Carolina Division ofAir Quality
1641 Mail Service Center
Raleigh,NC 27699-1641
E.Duty to Comply [15A NCAC 2Q .0508(i)(2)]
The Pen11ittee shall comply with all telms,conditions,requirements,limitations and restrictions set fm1h in this permit.
Noncompliance with any pennit condition except conditions identified as state-only requirements constitutes a violation of
the Federal Clean Air Act.Noncompliance with any permit condition is grounds for enforcement action,for pennit
termination,revocation and reissuance,or modification,or for denial ofa permit renewal application.
Yermtt mSl'i..5UTUb
Page 19
F.Circumvention -STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air
pollution.Unless otherwise specified by this permit,no emission source may be operated without the concunent operation of
its associated air pollution control device(s)and appurtenances.
G.permitModifjcations
1.Administrative Pennit Amendments [15A NCAC 2Q .0514]
The Permittee shall submit an application for an administrative pennit amendment in accordance with 15A NCAC 2Q
.0514.
2.Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q .0524 and 2Q .0505]
The Penmttee shall submit an application for an ownership change in accordance with l5A NCAC 2Q.0524 and 2Q
.0505.
3.Minor Pennit Modifications [15A NCAC 2Q .0515]
.The Pennittee shall subrnit an applicationfor a,minor permit modification in accordance with 15A NCAC 2Q :0515.
4.Significant Pemlit Modifications [15A NCAC 2Q .0516]
.-The Permittee shall submit an application for a significant pennit modification inaccordance with 15A NCAC 2Q
.0516.
5.Reopening for Cause [15A NCAC 2Q .0517]
The Permittee shall submit an applicationfor reopening for cause in accordance with 15A NCAC 2Q .0517..
H.Changes NQtRequjrjog PermjtModiticatjollS
1.Reporting Requirements
Any ofthe following that would result in new or increased emissions from the emission source(s)listed in Section 1
must be reported to the Regional Supervisor,DAQ:
a.changes in the information submitted in the application;
b.changes that modify equipll1ent or processes;Of
c.changes in the quantity or quality ofmaterials processed.
Ifappropriate,modifications to the permit maythen be made by the DAQ to reflect any necessary changes in the permit
conditions.Inno case are any new or increased emissions allowed that will cause a violation ofthe en:ilssio:n limitations
specified herein.
2.Section 502(h)(10)Changes [l5A NCAC 2Q .0523(a)]
a."Section S02(b)(10)changes"means changes that contravene an express pelmit tennor condition.Such changes
do not include changes that would violate applicable requirements or contravene federally enforceable permit
terms and conditions that are monitoring (including test methods),recordkeeping,reporting,or compliance
certification requirements.
o.The,Pemuttee may make Section 502(b)(10)changes without having the permit revised if:
1.the changes are not a modificationunder Title I ofthe Federal Clean Air Act;
11.the changes do not cause the allowable emissions under the permit to be exceeded;
111.the Permittee notifies the Director and EPA with 'written notification at least seven days hefore the change is
made;and
lV.the Permittee shall attach the notice to the relevant permit.
c.The written notification shall include:
1.a description ofthe change;
11.the date on which the change will occur;
lll.any change in emissions;and
IV.any pennit term or condition that is no longer applicable as a result ofthe change.
d.Section 502(b)(10)changes shall be made in the pennit the next time that the pemrit is revised or renewed,
whichever comes first.
3.OffPennit Changes [15A NCAC 2Q .0523(b)]
The Pelmittee may make changes in the operation or emissions without revising the pennit if:
a.the change affects only insignificant activities and the activities remain insignificant after the change;or
b.the change is not covered under any applicable requirement.
rermIt U~:-S,jUTUb
Page 20
4.Emissions Trading [ISA NCAC 2Q .OS23(c)J
To the extent that emissions trading is allowed under 15A NCAC 2D,including subsequently adopted 1111ximum
achievable control technology standards,emissions trading shall be allowed withoutpermit revision pursuant to 15A
NCAC 2Q .OS23(c).
LA.Reportjng Requjrements for Excess EmjssjoDs and permit Deviatioris
[ISA NCAC 2D .0535(1)and 2Q .0508(1)(2)]
~cess Emjssiem.s.:.:-means an emission rate that exceeds any applicable emission limitation or standard allowed byany
rule in Sections .0500,.0900,.1200,or .1400 ofSubchapter 2D;or by a pennit condition;or that exceeds an emission limit
established in a peimit issued under ISA NCAC 2Q .0700.(Note:Definitions ofexcess emissions under 2D .1110 and 2D
.1111 shallapply where defined by rule)
~Ocviations"-for the purposes ofthi5 condition,any action or condition 110t in accordance with the terms and conditions of
this perrnit including those attributable to upset conditions as well as excess emissions as defined above lasting less than
four hours.
Excess Emissions
1.Ifa source is required to report excess emissions lmder NSPS (ISA NCAC 2D .0524),NESHAPS (ISA NCAC 2D
.1110 or .1111),or the operating permit provides for periodic (e.g.,quarterly)reporting ofexcess emissions,reporting
shall be perfonned as prescribed therein.
2.Ifthe source is not subJcctto NSPS (ISA NCAC 2D .0524),NESHAPS (lSA NCAC 2D .1110 or .11 i1),ortllese
rules do NOT define "excess emissions,!!the Permittee shall repOli excess emissions in accordance with 15ANCAC
2D .0535 as follows:
a.Pursuant to 15A NCA.C 2D .0535,ifexcess emissions last for more than four hours resulting ii'om a malfunction,
a breakdown ofprocess or control equipment,or any other abnormal condition,the ovvner or operator shall:
1.notify the Regional Supervisor or Director ofany such occurrence by9:00 a.m.Eastem Time ofthe
Division's nexthusiness d.ay ofbecoming aware ofihe OCClllTe11ce arid provide:
(4'name and location ofthe facility;
'"nature and cause ofthe malfwlction orbreakdown;
~time when the malfunction or breakdown is first observed;
4)expected duration;and
(fI estimated rate ofemissions;
n.notify the Regional Supervisor or Director immediately when corrective measures have been accomplished;
aue!
111.submit to the Regional SupervisororDirector within 15 days a written repOli as describedin 15ANCAC 2D
.0535(1)(3).
P.;;:r.mitDeviatjons
C'.Pursuant to lSA NCAC 2Q .0508(1)(2),the Pennittee shall report deviations fi-om permit requirements (terms and
conditions)as follows:
Q.Notify the Regional Supervisor or Director ofall other deviations from pennit requirements not covered tmder
lSANCAC 2D .0535 quarterly.A written report to the Regional Supervisor shall include the probable cause of
such deviation and any cOlTective actions or preventative actions taken.The responsible official shall cCliif)'all
devlations frompenl1it requirements.
I.B.u.tb.£r·"Reqnirements under 15A NCAC 2D O~1~
The Permittee shall comply with all other applicable requirements contained in lSA NCAC 2D .0535,including ISA
NCAC 2D .OS3S(c)as follows:
L Any excess emissions that do not occur duringstart-up and shut-down shall be considered a violation ofthe
appropriate rule unless the oVv'ner or operator ofthe sources demonstrates to the Director,that the excess emissions are
3.result ofa malfimction.The Director shall consider,along -with any other pertinent lllformation,the criteria
contained in ISA NCAC 2D .OS3S(c)(I)through (7).
2.15A NCAC 2D .053S(g).Excess emissions during start-up and shut-down shall be considered a violation ofthe
appropriate rule ifthe owner or operator cannot demonstrate that excess emissions are unavoidable.
l'erml1 UHHJUTU6
Paee 21
J.Emergency Provisions [40 CFR 70.6(g)]
The Pennittee shall be subject to the following provisions with respect to emergencies:
1.An emergency means any situation arising from sudden and reasonably llllforeseeable events beyond the control ofthe
facility,including acts ofGod,which situation requires immediate corrective action to restore normal operation,and
that causes the facility to exceed a technology-based emission limitationunder the pelnllt,due to unavoidable
increases in emissions attributable to the emergency.An emergency shall not include noncompliance to the extent
caused by improperly designed equipment,lack ofpreventive maintenance,careless or improper operation,or operator
error.
2'.An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology-based
emission limitations ifthe conditions specified in 3.below are met.
3.The affinnative defense ofemergency shall be demonstrated through properly signed contemporaneous operating logs
or other relevaIit evidence that include infonnation as follows:
a.an emergentyoccurredand the Permittee can identify the cause(s)ofthe emergency;
b.the pelmitted facility was at the time being properly operated;
c.during the period ofthe emergency thePennittee took all reasonable steps to minimize levels ofemissions that
exceeded the standards or other requirements in the pennit;and
d.the Pennittee submitted notice ofthe emergency to the DAQ within t\vo working days ofthe time when emission
limitations were exceeded due to the emergency.This notice must contain a description ofthe emergency,steps
takcn to.mitigate emissions,and corrective actions taken.
4.In any enforcementproceeding,the Pemlittee seeking to establish the occurrence ofan emergency has the burden of
proof.
5.This provision is in addition to any emergency or upset provision contained in any applicable requirement specified
elsewhere herein.
K.Permit Renew'l [l5A NCAC 2Q .0508(c)and 2Q .0513(b)]
This permit is issued for a fixed term offive years for facilities subject toTitle IV requirements and for a term'not to
exceed five years in the case ofall otherfacilities.This permit shall expire at the end ofits tenn.Permit expiration
terminates the facility's right to operate unless a complete renewal application is submitted at least nine months befbre the
date ofpennit expiration.lftbe Pennittee or applicant has complied with 15A NCAC 2Q .0512(b)(1),this permit sliail not
expire until the renewal pennit has been issued or denied.All terms and conditions ofthis perrnit shaH remain in etTect
until therene'AlaI pen-nit has been issued or denied.
L.rsJ:j;!l to HallQr flednee AcHyity Not a Defense [15A NCAC 2Q .0508(1)(4)]
Itsh,aJl not be a dcfcl1$c.foraPennitteeinanenforcel1lentactiollthatitwouldhavebeennecessarytohalLorreducethe
pennitted activity in order to maintain compliance with the conditions oftllis peffilit.
M.llJJ.tyJ;ll.fi.nyide lnformatiolllsnhmittal ofinformation)[15A NCAC 2Q .0508(i)(9)]
1:'The Permittee shall furnish totheDAQ,in a timely manner,any reasonable infonnation that the Director mayrequest
in.l:Yritiu.g to cletennine whether cause exists for modifying,revoking and reissuing,or terminating the permit or.to
detetmine compliance with the permit.
2.Tlie Permittee shall furnish the DAQ copies ofrecords required to be kept by the penni!when such copies are
requested by the Director.For infonnation claimed to be confidential,the Pemrittee may furnish such records directly
to the EPA upon request along with a claim ofconfidentiality.
N.Dnty tll Snpplement [15A NCAC 2Q .0507(f)]
The Pelmittee,upon becoming aware that any relevant facts were omitted or incolTect information was submitted in the
pemlit application,shall promptly submit such supplementary facts or corrected information to the DAQ.The Permittee
shall also provide additional information as necessary to address any requirement that becomes applicable to the facility
after the date a complete permit application was submitted but prior to the release ofthe draft pennit.
o.[Mention of Records [15A NCAC 2Q .0508(f)and 2Q .0508 (1)]
The Permittee shallretain records ofall required monitoring data and supporting infonnation for a period ofat least five
years from the date ofthe monitoring sample,measurement,report,or application.Supporting information includes all
calibration and maintenance records and an original strip-chart recordings for continuous monitoring infonnation,and
copies ofall rcpOlts required by the permit.These records shall be maintained in a fonn suitable and readily available for
expeditious inspection and review.Any records required by the conditions ofthis pennit shall be kept on site and made
available to DAQ personnel for inspection upon request.
Permit 08830T06
Page 22
P Compliance Certjfie.finn [15A NCAC 2Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch,EPA,Region 4,61 Forsyth
Street,Atlanta,GA 30303)postmarked on or before March I a comphance certification (for the preceding calendar year)
bya responsible official with all federally-enforceable terms and conditions inthe pClmit,including emissions limitations,
standards,or work practices.It shall be the responsibility ofthe current owner to submit a compliance certification for the
entire year regardless ofwho ovvued the facility during the year.The compliance certification
shall comply with additional requirements as may be specified under Sections 114(a)(3)or 504(b)ofthe Federal Clean Air
Act.The compliance certification shall specify:
1.the identification ofeach tenn or condition ofthe pennit that is the basis ofthe certification;
2.the compliance status (with the tcnl1S and conditions ofthe pennit for the period covered by the cCltification);
3.whether compliance was continuous or intennittent;and
4.the methodes)used for detennining the compliance status ofthe source during the certification period.
Q.Cerfillcation by Responsible Qftjcja![15A NCAC 2Q .0520j
A responsible officialshall certifythe truth,accuracy,and completeness ofany application fonn,report,or compliance
certification required by this pelmit All certifications shall state that based on information and beliefformed after
reasonable inquiry;the statements and infonnation in the document are true,accurate,and complete.
R.Penni!Shield fur Applicable Requirements [15A NCAC 2Q .0512]
1.Compliance with the tenns and conditions ofthis pennit shall be deemed compliance with applicable requirements,
where such applicable requirements are included and specifically identified in the pennit as ofthe date ofpeInllt
Issuance.
2.A pennit shield shall not alter or affect:
a.the power ofthe Commission,Secretary oftbe Department,or Governor under NCGS 143-215.3(a)(12),or EPA
under Section 303 ofthe Federal Clean Air Act;
h~the"liabihtyofanowner or operator'ofa facility for anyviolation'of'applicablerequiteihe,iltsprlOr'to'tJle'effectiVe
date ofthe permit or at thetime ofpermit issuance:
c.theappbcable requirements under Title IV;or
d.the ability ofthe DirectoLor the EPA under Section 114 ofllie Federal Clean Air Act to obtain infoDl13Jionto
detennine'compliance ufthe facility with its,pennit
3.Apermit shield does not apply to any change made at a facility that does notrequire a permit or permit revision made
WIder 15A NCAC 2Q .0523.
4.Apennitshield does not extend tominorpenT'itmodiJications made under 15A NCAC 2Q .0515.
S.Ie.tminatjoD,Modification,and Re\,Orafjou offhe Ji'rrmjt elSANCAC 2Q .0519]
The Director may terminate,modify,or revoke and reissue this permit if:
L the illfon11ation containedilltheapplicati011"or presented,,in suppOlithereofis determined to be'incorrect;
2.the condition:;-under which the permit orpennit renewal was granted have changed;
3.violations ofconditions contained in the pennit have occurred;
4.the EPA requests that the pennit be revoked nnder 40 CFR 70.7(g)or 70.8(d);or
5.the Directorfmds that termination,modification,or revocation andreissuance ofthe permit is necessary to carry out
the purpose ofNCGS Cllapter 143,Article 2IB.
T.Insigniti!'llJ!f Activities [15A NCAC 2Q .0503j
Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted from
any applicable requirement or thatthe owner or operator ofthe source is exempted from demonstrating compliance vvith
any applicable requirement.The Pennittee shall have available at the facility at all times and made available to an
authorized representative upon request,docwnentation,including calculations,ifnecessalY,to demonstrate that an
einission source or activity is insignificant.
U.property Rights [15A NCAC 2Q .0508(i)(8)]
This pe1111it does not convey any property rights in eitherreal or personal property or any exclusive privileges.
Permit 08830T06
Page 23
v.InspecHnn and Entry [15A NCAC 2Q .0508(1)and NCGS 143-215.3(a)(2)]
1.Upon presentation ofcredentials and other documents as may be required by law,the Permittee shall allow the DAQ,
or an authorized representative,to perform the follovving:
a.entcr the Permittee1s premises where the pennitted facility is located or emissions-related activity is conducted,or
where records are kept under the conditions ofthe permit;
b.have access to and copy,at reasonable times,any records that are required to be kept under the conditions ofthe
permit;
c.inspect at reasonable times and using reasonable safety practices any source,equipment (including monitoring and
air pollution control equipment),practices,or operations regulated or required under the permit;and
d.sample or monitor substances or parameters,using reasonable safety practices,for the purpose of assuring
compliance with the pennit or applicable requirements atreasonable times.
Nothing in this condition shall limit the ability ofthe EPA to inspect orenter the premises ofthe Permittee under
Section 114 or other provisions ofthe Federal Clean Air Act.
2.No personshall refuse entry or access to any authorizedrepresentative ofthe DAQ who requests entry for purposes of
inspection,and who presents appropriate credentials,nor shallany person obstruct,hamper,or interfere with any such
authorized representative 'Nhile inthe process ofcarrying out his official duties.Refusal ofentry or access may
constitute grounds for pennit revocation and assessment ofcivil penalties.
w.Aum",1 Fee payment [15A NCAC 2Q .0508(i)(10)]
I.The Permittee shall pay all fees in accordance with 15A NCAC 2Q .0200.
2.Payment offees may be bycheck or money order made payable to the N.C.Department ofEnvironment and Natural
Resources.Annual pennit fee payments shall refer to the permit number.
3.If,within 30 days after being billed,the Pelmittee fails to pay an annual fee,the Director may initiate action to
terminate the permitunder 15A NCAC 2Q .0519.
X.AIlU1m!EmjssjnnJDven~eqJ!jrements [15A NCAC 2Q .0207J
The Permittee shall report by June 30 of each year the actual emissions ofeach air pollutant listed in 15A NCAC 2Q
.0207(a)from each emission somce within the facility during the previous calendar year.The report shall be in or on such
form as'may be established by the Director.The accuracy ofthe report shall be certified by a responsible official ofthe
facility.
y,Confjclen.tiJllln.furma [15A NCAC 2Q .0107 and 2Q.0508(i)(9)]
Wheneverthe Permittee submits intDnnation under a claim ofconfidentiality pursuant to 15A NCAC 2Q .0107,the
Pennittee may also snbrnit a copy ofall such infolmation and clairn directlyto the EPA upon request.All requests for
confidentiality must he in accordance with 15A NCAC 2Q .0107.
z.Construction andj)peratjon permits [15A NCAC 2Q .01 00 and .0300]
A construction and operating permit shall be obtainedby the Pennittee for any proposed new or modified facility or
emission source which is not exempted from having a permit prior to the beginning ofconstruction or modification,in
accordance with all applicahle provisions of 15A NCAC 2Q .0100 and .0300.
AA.Standard ApplicatjQu..EDrrn and Required Iuformatjon [15A NCAC 2Q .0505 and .0507]
The Permittee shall suhmit applications and required information in accordance with the provisions of 15A NCAC 2Q
.0505 and .0507.
BB.Financial Responsibility lind Compliance History [15A NCAC 2Q .0507(d)(3)]
The DAQ may require an applicant to submit a statement offinancial qualifications and/or a statement ofsubstantial
compliance history.
Permit 08830T06
Page 24
cc.Refrigerant Requirements (Stratospherjc Ozone and Climate protection)[15A NCAC 2Q .0501(e)]
1.Ifthe Permittee has appliances or refrigeration equipment,including air conditioning equipment,which use Class lor
II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40
CFR Part 82 Subpart A Appendices A and B,the Pennittee shall service,repair,and maintain such equipment
according to the work practices,personnel certification requirements,andcertified recycling and recoveryequipment
specified in 40 CFR Part 82 Snbpart F.
2.The Permittee shall not knowingly vent or othenvise release any Class I or II substance into the environment during
the repair,servicing,maintenance,or disposal ofany such device exceptas provided in 40 CFRPart 82 Subpalt F.
3.The Permittee shall comply widl all repOIting and recordkeeping requirements of40 CFR.82.166.Reports shall be
submitted to the EPA or its designee as required.
DD preventinn Qf 4ccjdental Releases -SectiQn 1J2(r)[15A NCAC 2Q .0508(h)]
lfdle Pemrittee is required tQ develop and register a Risk Management Plan with EPA pmsuant to Section 112(r)ofthe
Clean Air Act,then the Pennittee is required to register this plan in accordance with 40 CFR Part 68.
EE.Prevention of A('ddental Releases Gem'raJ ~'I 12(r)(1)-
FEDERALLY·ENFORCEABLE ONLY
Although a risk management plan may not be required,ifthe Permittee produces,processes,handles,orstores any amount
ofa listed hazardous substance,the Pennittee has a'general duty to take such steps as arc necessary to prevent the
accidental release ofsuch substance and to minimize the consequences ofany release.
FF.Title IV 4!1QwauCl'S [J 5A NCAC 2Q .0508(i)(I)]
This permit does not limitthe number ofTitle IV allowances held by the Permittee,but the Pennittee may not use
allowances as a detense to noncompliance withany other applicable requirement.The Pennittee's emissions may not
exceed any al1O\vances that the Jacility lawfully holds under Title IV afthe Federal Clean AirAct
GG..Ai.r..Pollution Emergenq'Epimde [J 5A NCAC 2D .0300]
Should the Directorofthe DAQ declare anAir Pollution Emergency Episode,the Pennittee willbe required to operate in
accordancc\iviththe Permittee's previously approved Emission ReductionPlall or,in the absence ofan approved plan,with
the appropriate requirements specified Ln l5A NCAC2D .0300.
HH RegistratjQn Qf Air po!lll1iJlJl5!l.J:ir.c.e:>U5A NCAC 2D .0200]
The Director ofthe DAQ lm:y require the Permittee to register a source ofair pollution.ff the Permittee is required to
register a source ofair po!lutio!t this registration and required infonnationwill be in accordance with ISA NCAC 2D
.0202(b).
n.Ambient Air Quality Standards [i5ANCAC 2D .0501(c)]
In addition to any control or manner ofoperation necessaryto meet emission standardsspecified inthis pennit,any source
ofair pollution shaltbe operated with such control or in such manner thatthe source shall not cause the ambient air quality
standards in 15A NCAC 2D .0400 to be exceeded at any point beyond the premises on which the somce is located.When
controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of
the ambient air quality standards or are required to create an offset,the pennit shall contain a condition requiring these
controls.
JJ.General EmissiQns Testing and RepQrting Requjrements [15A NCAC 2Q .0508(i)(16)]
Ifemissions testing is required by this pelmit or tlle DAQ or ifthe Pennittee submits emissions testing to the DAQ in
support ofa permit application or to demonstrate compliance,the Permittee shall perfoffil such testing in accordance with
15A NCAC 2D .2600 and follow the procedures ontlined below:
1.The Pelmittee shall suhmit a completed Protocol Snbmittal FOlm to the DAQ Regional Supervisor at least 45 days
prior to the scheduled test date.A copy ofthe Protocol Snbmittal Formmay be obtained fi·om the Regional
Supervisor.
2.The Permittee shall notify the Regional Snpervisor ofthe specific test dates at least 15 days prior to testing in order to
afford d,e DAQ ihe opportunity to have an observer on-site during the sampling program.
3.During all sampling periods,the Pennittee shall operate the emission source(s)under maximum Donnal operating
conditions or alternative operating conditions as deemed appropriate by the Regional Supervisor orhis delegate.
Permit U~~3UTU6
Page 25
4.The Permittee shall submit two copies ofthe test report to the DAQ.The test report shall contain at a minimum the
following 111fol111ation:
a.a description ofthe training and air testing experience ofthe person directing the test;
b.a certification ofthe tcst results by sampling team leader and facility representative;
c a summary ofemissions results and text detailing the objectives oftlle testing program.the applicable state and
federal regulations,and conclusions aboutthe testing and compliance status ofthe emission samee(s);
d.a detailed description ofthe tested emission souree(s)and sampling location(8)process flow diagrams,
engineering drawings,and sampling location schematics should be included as necessary;
e.all field,analytical,and calibration data necessary to verify that the testing was performed as specified in the
applicable test metliods;
f.example calculations for at least one test run using equations in the applicable test methods and all test results
including mtem1ediate parameter calculations;and
g.documentation offacility operating conditions during all testing periods and an explanation relating these
operating conditions to maximumnonnal operation.Ifnecessary,provide historical process data to verify
maximumnom1aloperation.
5.The testing requirement(s)shall be considered satisfied onlyupon writtenapproval ofthe test results by the DAQ.
6.The DAQ will review emission test results with respect exclusively to the specified testing objectives as proposed by
the Permittee and approved by the DAQ.
KK.Reopenjng for Calise [lSA NCAC 2Q .0517]
1.A pennit shall be reopened and revised under the following circumstances:
a.additional applicable requirements become applicable to a facility with remaining pemlit tennofthree or more
years;
b.additional requirements (including excess emission requirements)become applicable to a source covered by Title
IV;
c.the Director orEPA finds that the permit contains a material mistake or that inaccurate statements were made in
establishing the emissions standards of other tenTIS or conditions ofthe permit;or
d.the Director or EPA deterrnines that the permitmust be revised or revoked to assure compliance vvith the
applicable requirements.
2.Any pennit reopening shall be completed-or a revised pennit issued \\rithin 18 months after the applicable requirement
is promulgated.No reopening is required ifthe effective date ofthe requirement is after the expiration ofthe permit
tennunless the temlOfthe pennitwas extended pursuant to 1SA NCAC 2Q .0513(e).
3.Except for the state-enforceable only portion ofthe permit,the procedures set out in ISA NCAC 2Q .0507, .0521,or
.0522 shall be followed to reissue the pennit.lfthe State~ell'forceableonly portion ofthe permit is reopened,the
procedures in ISA NCAC 2Q .0300 shan be followed.The proceedings sball affect only those parts ofthe pemlitfor
which cause to reopen exists.
4.The Director shall notify the Permittee at least 60 days in advance ofthe date that the permit is to be reopened,except
in cases ofimminent threat to pubhe health or safety the notification period may be less than 60 days.
S.Within90 days,or 180 days ifthe EPA extends the response period,after receiving notitIcation from the EPA that a
permit needs to be temlinated,modified,orrevoked and reissued,the Director shall send to the EPA a proposed
detennination oftermination,modification,or revocation and reissuance,as appropriate.
LL.Reporting Requirements for Nou,.Qperatjog Equipment [ISA NCAC 2Q .OS08(i)(16)]
The Pennittee shall maintain a record ofoperation for permitted equipmentnoting whenever the equipment is taken from
and placed mto operation.During operation the monitm;ing recordkeepmg and reportingrequirements as prescribedby the
pennit shall be implemented within the monitoring period;
MM.Fugitive Dust Control Requirement [ISA NCAC 2D .0540]-STATE ENFORCEABLE ONLY
As required by ISA NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources,"tbe Pennittee shall not cause or
allow fugitive dust enlissions to cause or contribute to substantive complaints or excess visible emissions beyond the
property boundary.If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the
propertyboundaries for six minutes in anyone hour (using Reference Method 22 in 40 CFR,Appendix A),the owner or
operator may be required to submit a ftlgitive dust plan as described in 2D .OS40(f).
!1Fugitive dust emissions"means particu13te matter from process operations that does not pass through a process stack or
vent and that is generated within plant propeli)'bmmdaries from activities such as:unloading and loading areas,process
areas stockpiles,stockpile working,plant parking lots,and plantroads (including access roads and haul roads).
Permit 08830T06
Page 26
NN.L For modifications made pursuant to 15A NCAC 2Q .0501(c)(2),the Permittee shall file a Title V Air Quality
Pelmit Application for the air emission sauree(s)and associated air pollution control device(s)on or before 12
months after cOllU11cncing operation.
2.For modifications made pursuant to 15A NCAC 2Q .0501(d)(2),the Pemlittee shall not begin operation oftlre air
emission sauree(s)and associated air pollution control device(s)until a Title V Air Quality Pennit Application is
filed and a construction and operation pernlit following the procedures ofSection .0500 (except for Rule .0504 of
this Section)is obtained.
3.For modifications made pursuant to 502(b)(10),illaccordance with 15A NCAC 2Q .0523(a)(1)(C),the Pernlittee
sball notify the Director and EPA (EPA -Air Planning Branch,61 Forsyth St.,Atlanta,GA 30303)in writing at
least seven days before the change is made.The written notificationshall include:
a.a description of the change at the facility;
b.the date on which the change will occur;
c.any change in emissions;and.
d.any permit term or condition that is no longer applicable as a result ofthe change.
In addition to this notification requirement,with the next significant modification or Air Quality Permit renewal,
the Permittee shall submit a page "E5"ofthe application forms signed by the responsible ofIicial verifying that the
application for the 502(b)(10)change/modification,is true,accurate,and complete.Further note that
modifications made pursuant to 502(b)(10)do not relieve the Permittee from satisfying preconstmction
requirements.
Permit 08830T06
Paee 27
ATTACHMENT
List of Acronyms
AOS
BACT
Btn
CEM
CFR
CAA
DAQ
DENR
EMC
EPA
FR
GACT
HAP
MACT
NCAC
NCGS
NESHAPS
NOx
NSPS
OAH
PM
PMIO
POS
PSD
RACT
SIC
SIP
S02
tpy
VOC
Alternate Operating Scenario
Best Available Control Technology
British thennal unit
Continuous Emission Monitor
Code ofFederal Regulations
Clean Air Act
Division ofAir Quality
Department ofEnvirom11ent and Natural Resources
Enviromnental Management Commission
Environmental Protection Agency
Federal Register
Generally Available Control Technology
Hazardous Air Pollutant
Maximum Achievable Control Technology
North Carolina Administrative Code
North Carolina General Statutes
National Emission Standards for Hazardous Air Pollutants
Nitrogen Oxides
New Source Perfonnance Standard
Office ofAdministrative Hearings
Particulate Matter
Particulate Matter with Nominal Aerodynamic Diameter of10 Micrometers or Less
Primary Operating Scenario
Prevention of Significant Deterioration
Reasonably Available Control Technology
Standard Industrial Classification
State Implementation Plal1
Sulfur Dioxide
Tons Per Year
Volatile Orgal1ic Compound

March 7, 2017

Sent Via Email – [e-mail]
Mr. Richard Lovett
Environmental Compliance and Support Manager
City of Greensboro - Field Operations Department
PO Box 3136
Greensboro, NC 27402-3136

Re: Ebuffer Inspection Schedule Revision Request
Groundwater Corrective Action
City of Greensboro White Street Landfill Phase II – C&D Over MSW
Guilford County
Solid Waste Permit Number 4103
DIN 27484

Dear Mr. Lovett,

The NC Solid Waste Section has completed a review of the Ebuffer Inspection Schedule Revision Request
dated March 3, 2017 (DIN 27483) submitted on your behalf by S&ME, Inc. for the White Street Landfill
Phase II – C&D Over MSW, NC Solid Waste Permit Number 4103. Groundwater corrective action has been
ongoing at the landfill since 2009.

The Solid Waste Section approved the City’s selected remedy for this facility on June 24, 2008 that
included the implementation of Monitored Natural Attenuation (MNA), Phytoremediation (Ebuffer), and
maintaining consistent contours (DINs 4964 and 4970). The City’s Corrective Action Plan dated April 2009
was approved on May 14, 2009 (DINs 7393 and 7422).

The City of Greensboro is requesting the following regarding changes to the inspections for the Northern
and Southern Ebuffers (Phytoremediation stands):
x Twice per year conduct full inspections of the Ebuffers, one during the Spring new growth, and
the other during late Summer to early Fall before the trees begin to change color. A
phytoremediation assessment log for the Northern and Southern Ebuffers would be completed
at this time.
x Monthly inspections of the Ebuffers including visual observations for animal damage, the need to
mow the grass between the rows of trees and along the outer perimeter trees, and the need for
weed control around the base of the trees.

As a result, the Ebuffer Inspection Schedule Revision Request is approved as described. If you have any
questions or concerns regarding this letter, please feel free to contact me by phone at 828.296.4706 or
by email at [e-mail]. Thank you for your cooperation with this matter.

Sincerely,

Jaclynne Drummond
Compliance Hydrogeologist
Solid Waste Section, Division of Waste Management
NCDEQ

cc sent via email: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
John Patrone, Environmental Senior Specialist
Christine Ritter, Permitting Hydrogeologist
Ming Chao, Permitting Engineer
Ed Henriques, S&ME, Inc.
Digitally signed by Jaclynne Drummond
Date: 2017.03.07 12:54:23 -05'00'
City of Greensboro | White Street C&D Landfill – Permit Amendment Appendix B – Engineering Plan

B
Appendix B – Engineering
Plan

Engineering Plan
White Street C&D Landfill
Permit Renewal
Greensboro, North Carolina
December 2016
Revised May 2017

HDR Engineering, Inc. of the Carolinas
440 S Church Street, Suite 1000, Charlotte, NC 28202-2075 704.338.6700 NC License F0116

City of Greensboro | White Street C&D Landfill – Engineering Plan Contents
Contents
Contents ......................................................................................................................................... i
1.0 Introduction ........................................................................................................................ 1
1.1 Background Information ................................................................................................. 1
1.2 Responsible Party .......................................................................................................... 1
1.3 Projected Use after Closure ........................................................................................... 1
2.0 Engineering and Design ..................................................................................................... 2
2.1 Existing Features ............................................................................................................ 2
2.2 Facility Design ................................................................................................................ 2
2.3 Final Grading Plan .......................................................................................................... 2
2.4 Airspace Calculations ..................................................................................................... 2
2.5 Groundwater Monitoring ................................................................................................. 2
3.0 Construction and Operations ............................................................................................. 5
3.1 Filling Procedures ........................................................................................................... 5
3.2 Site Development/Proposed Final Contours .................................................................. 5

Figures
Figure 1 Tonnage History ............................................................................................................. 3
Figure 2 Phase II Estimated Life Expectancy .............................................................................. 4

i
City of Greensboro | White Street C&D Landfill – Engineering PlanIntroduction

1
1.0 Introduction
The City of Greensboro, North Carolina, (Greensboro) is proposing to renew the permit to
operate for the White Street Construction and Demolition Debris (C&D) Landfill in Guilford
County, North Carolina.
The information contained in this submittal is intended to fulfill the requirements of North
Carolina Solid Waste Management Rule 15A NCAC 13B .0535(b) for the amendment of the
operating permit.
1.1 Background Information
In November of 1995, HDR, on behalf of the City of Greensboro, submitted a Transition Plan for
the Phase II sanitary landfill of the White Street Landfill. The Transition Plan was approved in
July of 1996, and Olver Incorporated certified closure of the sanitary landfill in March of 1999.
After North Carolina Department of Environmental Quality (NCDEQ) approval of the Transition
Plan, the City of Greensboro submitted a permit application to dispose of C&D over top of the
closed municipal solid waste (MSW) in Phase II. NCDEQ issued the original C&D over MSW
permit for Phase II in July of 1998. The following is a history of the C&D permits received for the
White Street C&D Landfill. A copy of the current PTO, issued in 2012, is included in Appendix A
of this permit amendment.
Permit Type Date Issued
Permit to Operate (PTO) – Stage I January 7, 1998
PTO Modification – Stage II October 7, 1998
PTO Modification – Stage III April 15, 2000
PTO Amendment – Continued Operation May 25, 2006
PTO Amendment – Continued Operation March 30, 2012

1.2 Responsible Party
The individual responsible for the operation and maintenance of the site is the Solid Waste
Disposal Manager for the City of Greensboro:
Solid Waste Disposal Manager
[phone]
2503 White Street
Greensboro, NC 27405
1.3 Projected Use after Closure
After closure of the landfill, the site will be maintained and monitored. No post-closure uses
have been identified or are planned for the site at this time.
City of Greensboro | White Street C&D Landfill – Engineering Plan Engineering and Design
2.0 Engineering and Design
2.1 Existing Features
An overall Site Plan with the existing features of the site can be found on Drawing CD-77B. This
drawing displays features of the facility such as, unlined closed MSW Phase II (135 ac),
permitted C&D Landfill (26 ac), closed C&D Landfill (34 ac), active C&D landfill (31 ac),
borrow/stockpile areas and maintenance facilities.
2.2 Facility Design
This site maintains the following regulatory buffers (per Rule 15A NCAC 13B .0540 (1):
• A 50-foot buffer between property line and waste.
• A 500-foot buffer from private dwellings and wells to waste.
• A 50-foot buffer from streams and rivers to waste.
2.3 Final Grading Plan
The proposed top of intermediate cover grades for the remaining portion of Phase II can be
found on Drawing C-02. The proposed grades are 4 horizontal to 1 vertical (4H:1V) and reach
an elevation of 870 feet above mean sea level. The final cap thickness is an additional two feet
on top of the intermediate grades.
2.4 Airspace Calculations
The permitted gross capacity of the C&D landfill from the March 12, 2012 Permit to Operate
(PTO) is 2,525,443 cubic yards. The current total gross capacity of the C&D landfill on top of the
closed MSW landfill is 2,370,000 cubic yards at 4H:1V sideslopes after revised intermediate
grades were sent to NCDEQ on February 21, 2014. Through June 2016, approximately
1,722,981 tons of waste has been disposed of at the C&DLF consuming 1,450,536 cubic yards.
This equates to a waste density of 1.19 tons per cubic yard. Over the past five years the
average annual waste accepted is 37,531 tons. Based on the cumulative waste density and five
year average annual tonnage the remaining capacity would be full in October 2042. Reference
Figure 1 and Figure 2 for updated tonnage history and life projection estimates.
2.5 Groundwater Monitoring
A Water Quality Monitoring Plan was originally prepared by S&ME, Inc. (dated December 2007).
The monitoring plan and related Corrective Action Plan (S&ME, April 2009) can be found in
Appendix D.

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City of Greensboro | White Street C&D Landfill – Engineering Plan Construction and Operations
3.0 Construction and Operations
The City of Greensboro will continue to develop the landfill in a manner that promotes runoff to
the existing erosion control features. Benches will be graded to drain to sediment basins.
All aspects of the current operation of the facility are anticipated to continue. Operation hours
are currently from 7:00 a.m. to 4:50 p.m., Monday through Friday and 7:00 a.m. to 1:00 p.m. on
Saturdays. The landfill is closed on Sundays and specified holidays. These hours and days of
operation are subject to change. Staff will be stationed in the scalehouse to screen and manage
incoming trucks, while an additional staff person will be responsible for handling the daily
placement of waste. Information regarding on-site equipment and other operational issues is
included in the Operations Plan in Appendix C.
The site currently has a lockable gate at the main entrance from White Street, which is locked at
the end of each working day. Fencing has been constructed around the site to further control
access.
In the event there is a period when the scales are temporarily out of operation, the incoming
material will be handled on a cubic-yardage basis. The same scales and scale house will
continue to be used for the vertical expansion. Please refer to the Operations Plan in Appendix
C for more information on the operations of the facility.
3.1 Filling Procedures
Please see the Operations Plan in Appendix C for the filling procedures.
3.2 Site Development/Proposed Final Contours
Please refer to Drawing C-02 for the proposed top of intermediate cover contours for the active
C&D landfill. Please refer to Appendix F for the Closure/Post Closure Plan for this site.

5
City of Greensboro | White Street C&D Landfill – Permit Amendment Appendix C – Operations Plan

C
Appendix C – Operations
Plan

Operations Plan
White Street C&D Landfill
Permit Renewal
Greensboro, North Carolina
December 2016
Revised May 2017

HDR Engineering, Inc. of the Carolinas
440 S Church Street, Suite 1000, Charlotte, NC 28202-2075 704.338.6700 NC License F0116

City of Greensboro | White Street C&D Landfill – Operations Plan Contents
Contents
Contents ......................................................................................................................................... i
1.0 Introduction ........................................................................................................................ 1
2.0 Personnel Structure ........................................................................................................... 1
3.0 Personnel Certifications and Training ................................................................................ 2
4.0 Hours of Operation ............................................................................................................. 2
5.0 Equipment Requirements ................................................................................................... 3
6.0 Inclement Weather Operations .......................................................................................... 3
7.0 Traffic Routing .................................................................................................................... 3
8.0 Litter Control ....................................................................................................................... 4
9.0 Odor, Noise, and Dust Control ........................................................................................... 4
10.0 Waste Placement ............................................................................................................... 5
11.0 Asbestos ............................................................................................................................ 5
12.0 Cover Requirements .......................................................................................................... 5
12.1 Weekly Cover ................................................................................................................. 6
12.2 Intermediate Cover ......................................................................................................... 6
13.0 Vector Control .................................................................................................................... 6
14.0 Explosive Gases Control .................................................................................................... 6
14.1 Perimeter Explosive Gas Monitoring Well Placement .................................................... 7
14.2 Well Construction ........................................................................................................... 8
14.3 Sampling Procedures ..................................................................................................... 8
14.4 Emergency Response Plan ............................................................................................ 8
15.0 Prevention of Fires ............................................................................................................. 9
16.0 Waste Screening Program ................................................................................................. 9
16.1 Waste Receiving and Inspection .................................................................................. 10
16.2 Waste Screening .......................................................................................................... 10
17.0 Hazardous Waste Contingency Plan ............................................................................... 11
18.0 Access Control ................................................................................................................. 11
19.0 Drainage, Sedimentation and Erosion Control ................................................................. 11
20.0 Water Protection .............................................................................................................. 12
21.0 Maintenance ..................................................................................................................... 12
21.1 Repair of Security Control Devices ............................................................................... 12
i
City of Greensboro | White Street C&D Landfill – Operations Plan Contents
21.2 Erosion Damage Repair ............................................................................................... 12
21.3 Correction of Settlement, Subsidence, and Displacement ........................................... 12
21.4 Repair of Run-On/Run-Off Control Structures .............................................................. 13
21.5 Leachate Seep Repairs ................................................................................................ 13
22.0 Benchmarks ..................................................................................................................... 13
23.0 Record Keeping ............................................................................................................... 13

Tables
Table 1 Equipment and Personnel ................................................................................................ 3

Figures
Figure 1 Hours of Operation ......................................................................................................... 2
Figure 2 Landfill Rules .................................................................................................................. 2
Figure 3 Traffic Routing ................................................................................................................ 4
Figure 4 Typical Benchmark Signage ......................................................................................... 13
Figure 5 Recordkeeping .............................................................................................................. 13

Forms
Form 1 Waste Screening ............................................................................................................ 15
Form 2 Report of Attempted Disposal of Hazardous or Prohibited Materials ............................. 16
Form 3 Fire/Explosion Report Form ............................................................................................ 18

Attachment 1
Attachment 1 – Hazardous Materials Contingency Plan

ii
City of Greensboro | White Street C&D Landfill – Operations Plan Introduction
1.0 Introduction
The purpose of this section is to identify protocols for the overall operation and maintenance of
the White Street Landfill Construction and Demolition Debris (C&D) disposal facility. This plan
has been prepared in accordance with North Carolina Department of Environmental Quality
(NCDEQ) rules. A detailed drawing of the landfill’s development from existing conditions to final
contours is presented in Appendix G of the 2016 Permit Amendment. By definition, the C&D
waste stream is originated solely from construction, demolition, and remodeling or repair
operations on pavement, buildings or other structures. In addition, the NCDEQ Division of
Waste Management (DWM) has approved other inert wastes (such as land clearing debris, but
not yard waste) if they can be demonstrated to be inert through the toxicity characteristic
leaching procedure. The current waste screening program will continue to be utilized by the
landfill staff for determination of accurate disposal areas and the prevention of prohibited wastes
as described in Rule .542 (e).
The City of Greensboro proposes to continue operation of the current C&D disposal site as
previously approved and permitted May 25, 2006 (Permit #41-03). The proposed disposal area
continues to operate within the area of the facility known as Phase II which is a closed MSWLF
unit subject to the appropriate section of the .1600 rules (Drawing CD-77B). Regulatory closure
of Phase II has been previously certified as closed in accordance with promulgated guidelines.
2.0 Personnel Structure
Responsibility for overall facility management and operation rests with the Solid Waste Disposal
Manager.
Solid Waste Disposal Manager
[phone]
2503 White Street
Greensboro, NC 27405
This individual is designated as the contact person for regulatory compliance, and is responsible
for ensuring adequate personnel and equipment in order to operate the facility in compliance
with approved permit documents and the North Carolina Solid Waste Management Rules.
Landfill supervisory staff includes the Solid Waste Disposal Manager, the Landfill Supervisor,
the Environmental Compliance Supervisor, the Yard Waste and Compost Supervisor, and the
Scalehouse Supervisor. In addition to the supervisory staff, the landfill now operates with full
time heavy equipment operators, full time heavy equipment mechanics, full time maintenance
workers, full time heavy equipment operators at the yard waste and compost site, landfill
technicians, and full time scale operators.
1
City of Greensboro | White Street C&D Landfill – Operations Plan Personnel Certifications and Training
3.0 Personnel Certifications and Training
The Solid Waste Disposal Manager and Landfill Supervisor maintain their certifications as a
Manager of Landfill Operations (MOLO), issued by the Solid Waste Association of North
America (SWANA).
In compliance with North Carolina GS 130-309.25, all heavy equipment operators and the
landfill technician maintain certification as Landfill Operation Specialists as issued by the North
Carolina Chapter of SWANA (NCSWANA). These staff members are then continuously
recertified through on-site training as well as through industry and NCSWANA events. All
training records are available at the scalehouse.
Personnel trained in landfill operations are on duty at all times while the facility is open for public
use and at all times during active waste management operations.
4.0 Hours of Operation
The landfill is open for operation between the hours of 7:00 AM and 4:50 PM, Monday through
Friday and from 7:00 AM to 1:00 PM on Saturday. The landfill is closed on Sundays except
where prior permission has been granted to receive wastes for special instances such as a
natural disaster. The observed holidays are New Year’s Day, Martin Luther King Jr. Day, Good
Friday, Memorial Day, Independence Day, Labor Day, Veteran’s Day, Thanksgiving Day and
Christmas Day. The sign giving the hours of operation for the landfill is shown in Figure 1.
Figure 1 Hours of Operation Figure 2 Landfill Rules
2
City of Greensboro | White Street C&D Landfill – Operations Plan Equipment Requirements
5.0 Equipment Requirements
The landfill will utilize two compactors and two bulldozers. The landfill will utilize a bulldozer for
soil placement in the routine covering of the waste. Also available for operational and
compliance activities are a motorgrader and water truck. A full inventory list of current
equipment and landfill personnel is presented in Table 1. Equipment is subject to change based
on operational needs.
Table 1 Equipment and Personnel
Equipment Quantity
Bulldozers 4 Landfill Compactor 2 Motorgrader 1
Track Excavator 1 Articulated Dump Trucks 2
Position
Manager 1 Landfill Supervisor 1 Environmental Supervisor 1 Scalehouse Supervisor 1 Heavy Equipment Operators (full time) 5
Heavy Equipment Operators (part time) 2 Heavy Equipment Mechanics 2 Maintenance Workers 2 Landfill Technician 1 Scale Operators 2

6.0 Inclement Weather Operations
During periods of heavy rainfall or other adverse weather conditions, the working face of the
waste disposal area will be kept as close as possible to the landfill service roads while allowing
for safe and orderly dumping from the haulers. The waste will be covered in compliance with
applicable regulations.
7.0 Traffic Routing
An entrance sign is posted on the front gate stating operating hours as well as emergency
contact information (Figure 1). An additional sign is also posted immediately inside the front
gate stating the facility name, permit number, operating hours (Figure 2), landfill rules and a list
of banned disposal items. Signs are posted at regular intervals along the landfill access roads
indicating speed limit and directions to the applicable disposal area (Figure 3).
3
City of Greensboro | White Street C&D Landfill – Operations Plan Litter Control

Figure 3 Traffic Routing
All trucks entering the landfill are required to weigh in at one of two scales at the scalehouse.
The scales are operated by North Carolina Department of Agriculture Certified Weigh masters.
The scales are calibrated and cleaned on a regular basis. Automobiles and pickup trucks are
also required to weigh in.
The roads that allow access to the site and to monitoring locations are of all weather
construction and maintained in good condition.
8.0 Litter Control
Litter control is a prime requisite in the proper operation of the landfill. In order to effectively
control litter and windblown debris, the working face is kept as small as possible and waste is
compacted as soon as possible after unloading. Cover material is applied at least once weekly
and when the working face exceeds one-half acre. Cover is available daily and will be placed at
more frequent intervals if necessary to control blowing litter. Temporary litter fences will be
installed downwind of and in close proximity to the working face to prevent windblown debris.
The disposal area as well as the landfill property and the streets feeding into the landfill are
inspected and any fugitive debris is removed on a daily basis.
9.0 Odor, Noise, and Dust Control
Odors which emanate from the management of C&D wastes are generally limited to within a
short distance of the working face. The covering of the wastes as required prevents odors from
becoming a nuisance.
The access road from the scalehouse to the waste disposal unit is paved. All other service and
operating roads on the operating landfill unit are graded and maintained with stone as
4
City of Greensboro | White Street C&D Landfill – Operations Plan Waste Placement
necessary to maintain smooth, well-drained surfaces. During dry conditions, operating roads will
be sprayed with water to control dust issues. The paved access roads are washed periodically
to maintain an overall neat appearance of the landfill.
Noise resulting from landfill equipment is limited to the period of time during operating hours. To
further reduce the possibility of noise nuisance, a vegetative buffer of coniferous and deciduous
trees and other vegetation is maintained between the operating areas and other areas not
designated for landfill operations. All landfill equipment is equipped with mufflers or similar
noise-dampening devices. The on-site landfill maintenance facility maintains all landfill
equipment in top operating condition further eliminating potential noise nuisances from
equipment operations.
10.0 Waste Placement
Waste will only be disposed of inside the area labeled limits of C&D waste as shown on Drawing
CD-77B. Drawing CD-77B also indicates the buffers as maintained. The existing contours of the
current waste placement operation as well as closed MSW areas are identified on Drawing C-
01. Waste is to be placed vertically over existing construction and debris material and closed
MSW areas. The removal of solid waste from the C&D landfill is prohibited.
Solid waste unloading at the landfill is controlled to prevent disposal in locations other than
those permitted. Such control is also used to confine the working face to a minimum width,
facilitating a safe and efficient operation. The waste shall be managed in the smallest area
(working face) feasible. Upon dumping, the waste will be spread and compacted as densely as
practical into cells utilizing a bulldozer or a compactor.
The fill sequence using multiple lifts allows filling to occur uniformly across the site. This
provides for elimination of depression areas and facilitates proper storm water movement and
management. Waste disposal activities will progress in approximately 10 foot lifts across the
landfill footprint as shown on (Drawing C-01).
11.0 Asbestos
The White Street Landfill does not accept asbestos. Asbestos is listed as a banned material on
the signage in Figure 2 and staff is trained to detect and prevent disposal through the waste
screening program.
12.0 Cover Requirements
A significant volume of soil is required to provide adequate cover and allow for safe and efficient
waste disposal operations. In order to provide for these requirements, the landfill maintains a
large permitted borrow area (Drawing CD-77B). The landfill also maintains a stockpile for soil
that is brought to the landfill from outside sources (Drawing CD-77B). These outside soil
sources must be approved by staff prior to being brought to the landfill.
5
City of Greensboro | White Street C&D Landfill – Operations PlanVector Control
6
12.1 Weekly Cover
In compliance with the latest rules as promulgated regarding management of C&D waste, the
waste will be covered with six inches of earthen material at least once per week and when the
working face exceeds one-half acre. The landfill will also have available daily cover material if
needed to apply in times of adverse weather conditions. At this time, the landfill will be utilizing
earthen material from the above described soil sources to cover the waste. This material has
been demonstrated to control odors, vectors, blowing litter, and fires. The weekly cover soil
requirement is 82,000 cubic yards assuming a 10:1 waste to soil ratio.
12.2 Intermediate Cover
Intermediate cover consisting of a total of 12 inches of earthen material is applied to all areas
which will not have any waste placement occurring for a period of three months or more. Areas
which have received intermediate cover are graded to facilitate proper drainage and to prevent
any ponding of water. Once proper grading and drainage has been achieved, temporary grass
will be planted. Any erosion or damage to the intermediate cover is repaired on a routine
basis. See Section 1.2 of the Closure/Post Closure Plan for the definition of vegetation. During
construction of the final cap, the top six inches of the intermediate cover will be removed to
prepare for the final cap.
13.0 Vector Control
The City will prevent or control on-site populations of disease vectors using techniques
appropriate for the protection of human health and the environment. For purposes of this item,
"disease vectors" means any rodents, flies, mosquitoes, or other animals or insects, capable of
transmitting disease to humans. Vectors are generally attracted by opportunities for food and
shelter. C&D waste is not a food source for many vectors. Vectors seeking shelter in the waste
mass can be discouraged by covering of the waste and proper grading to prevent ponding of
water. If vectors become a problem, a licensed exterminator or other legal means of control
shall be implemented.
14.0 Explosive Gases Control
With the C&D disposal operations occurring on top of a closed MSW facility, the landfill monitors
for migration of explosive gases. A gas monitoring system has been constructed along the east
side of the landfill which abuts Rankin Mill Road. All buildings and enclosed structures on the
landfill are monitored as part of the routine explosive gas monitoring program (Drawing CD-
79B). Routine monitoring for gas migration is performed in accordance with Rule .1626 part
(4)(b) on a quarterly basis to ensure that the following compliance levels for methane and
hydrogen sulfide concentrations are not exceeded: 1) the concentration of methane or hydrogen
sulfide gas generated by the facility does not exceed 25% of the lower explosive limit (LEL) for
the gas in facility structures (1.25% methane, 1.00% hydrogen sulfide); 2) the concentration of
methane or hydrogen sulfide gas migrating from the landfill does not exceed the LEL for
methane at the facility property boundary (5% methane, 4.00% hydrogen sulfide).
City of Greensboro | White Street C&D Landfill – Operations Plan Explosive Gases Control
Routine monitoring for gas migration will be performed on a quarterly basis to ensure that the
following compliance levels for explosive gas concentrations are not exceeded.
• The concentration of methane or hydrogen sulfide gas generated by the facility does not
exceed 25 percent of the respective lower explosive limit (LEL) in facility structures (1.25
percent methane, 1.00 percent hydrogen sulfide).
• The concentration of methane or hydrogen sulfide gas migrating from the Landfill does
not exceed the respective LEL at the facility property boundary (5 percent methane, 4
percent hydrogen sulfide).
The monitoring device that will be used will be a combustible gas indicator (CGI).
If concentrations are measured at greater than 25 percent of the LEL in facility structures, then
the landfill must immediately take all necessary steps to ensure protection of human health and
shall notify the NCDEQ-DWM. Within seven days of detection, the gas levels detected and a
description of the steps taken to protect human health shall be placed in the operating record.
Within 60 days of detection, a remediation plan describing the nature and extent of the problem
and the proposed remedy for gas releases shall be placed in the operating record, the
remediation plan shall be implemented, and the NCDEQ-DWM shall be notified.
Additional gas probes may be installed as required. They will be installed in a similar manner as
the existing gas probes.
14.1 Perimeter Explosive Gas Monitoring Well Placement
According to Rule .1624 (4), soil, hydrogeologic and hydraulic conditions, and proximity of
structures and property boundaries should be considered when locating gas monitoring wells
and determining monitoring frequency.
Landfill structures consist of the Administration Building, Compliance and Compost Operations
Office, Maintenance Shop, Phase II LFG blower building, equipment and maintenance shed at
the compost site, and the Operations Building. The landfill also operates a landfill gas collection
system on Phase II. The Phase II system is comprised of vertical extraction wells, a main
header pipe, condensate traps, a flare, and a blower station.
The Phase II area of the landfill is bounded on the north and west sides by North Buffalo Creek,
on the east by Rankin Mill Road, and on the south by landfill property. North Buffalo Creek will
act as a natural barrier between the landfill and adjoining properties on the north side of the
creek. Four locations labeled Surface Monitoring Points have been identified on the southern
bank of North Buffalo Creek and are monitored as part of the quarterly landfill gas monitoring
program.
It will be necessary to monitor gas migration along the landfill property line at Rankin Mill Road,
and the church property on Rankin Mill Road. As shown on Drawing CD-79B six wells are
located along Rankin Mill Road and two wells are located near the church property.
Permanently mounted gas monitors have been placed in the Administration Building,
Compliance and Compost Operations Office, Maintenance Shop, Phase II LFG blower building,
7
City of Greensboro | White Street C&D Landfill – Operations Plan Explosive Gases Control
and the Operations Building. These structures are also monitored during the quarterly
monitoring event.
14.2 Well Construction
All of the methane monitoring wells were constructed of 2-inch PVC pipe placed in a 6-inch
diameter bore hole. The screened interval ranged from 5-10 feet, terminating just above the
seasonally high water table or at auger refusal. A sand filter pack was placed around the screen
and extends 2 feet above the top of the screen. A bentonite seal was placed above the filter
pack. The 2-inch casing pipe is protected by a 4-inch square steel outer casing with a locking
steel cover. The outer casing is embedded in a 2’x2’x4” concrete pad.
14.3 Sampling Procedures
The monitoring device that will be used during each quarterly monitoring event will be a portable
combustible gas indicator. This is equipped with a flexible hose and rigid probe. Calibration of
the instrument will be performed in accordance with the manufacturer’s specifications.
Personnel designated to perform the monitoring program will be trained in the operation,
maintenance, and calibration of the monitoring equipment. The following operating procedures
and safety precautions will be adhered to by all personnel when monitoring for methane gas.
1. At least two people should be present at all times when monitoring for explosive gases.
2. At a minimum, safety glasses, gloves, work boots, will be worn. Other appropriate
personal protective equipment will be worn as needed.
3. Smoking and open flames are strictly prohibited at all times during the monitoring event.
4. Fire extinguishers will be readily available when performing the monitoring event.
5. Personnel performing the monitoring event will have the City radio readily available
which has direct access to emergency personnel.
14.4 Emergency Response Plan
In the event gas levels are detected that exceed allowable limits, the emergency response plan
will be as follows.
1. For 100% LEL at landfill boundaries less than 250 feet from structures:
a. Greensboro Fire Department and Hazardous Material Team will be notified.
b. Implement procedures as outlined in Rule .1624 (4).
2. For 100% LEL at landfill boundaries where the distance is greater than 250 feet from
structures:
a. Notify the Division.
3. For structures detection levels greater than 25% LEL:
a. Evacuate the structure immediately.
b. Notify Greensboro Fire Department and Hazardous Material Team.
8
City of Greensboro | White Street C&D Landfill – Operations Plan Prevention of Fires
15.0 Prevention of Fires
In accordance with the Clean Air Act, open burning is prohibited at this site, unless approved by
the Division for the infrequent burning of land clearing debris as generated from natural
disasters or emergency clean-up operations. In order to control accidental fires occurring at the
site, the following preventative measures have been taken:
1. The scale attendants and equipment operators screen incoming waste loads for signs of
hot loads such as smoke, steam, or heat being released from the waste. If evidence of a
hot load is detected, the hauler is diverted to the paved road directly east of the
scalehouse. This prevents the load from entering the disposal unit and provides a safe
area for emergency crews to manage the situation.
2. As described in the City of Greensboro Smoking Policy, smoking is confined to
designated areas only. Smoking is not allowed within the footprint of the disposal unit, in
any of the landfill equipment, or the landfill buildings. Smoking is also disallowed at the
fuel dispensing station, in the vicinity of any of the landfill gas collection system
structures or facilities or other fire sensitive area.
3. Motorized equipment is not parked near fuel dispensing stations longer than necessary
for refueling.
4. Fuel spills are reported immediately and contained by berming the area and cleaned up
immediately using an approved absorbent material.
5. Landfill equipment does not remain on the active disposal area of the site overnight.
6. Landfill equipment is washed routinely and kept free of ignitable debris.
7. Landfill equipment is maintained through a rigorous on-site routine preventative
maintenance program to ensure integrity of all operating systems and fluid conveyance
lines.
8. Dead trees, brush, or vegetation, adjacent to the landfill are removed immediately, and
grass and weeds are routinely mowed so that brush fires cannot spread to the landfill.
The landfill employs several types of large bush-hog and lawn type mowers to
accomplish this task.
In the event of a fire, the Greensboro Fire Department is notified immediately. Fires and
explosions that occur at the C&D Landfill will be verbally communicated to the Division within 24
hours and followed by written communication within 15 days. Written notification will include the
suspected cause of fire or explosion, the response taken to manage the incident, and the
action(s) to be taken to prevent the future occurrence of fire or explosion.
16.0 Waste Screening Program
In order to assure that prohibited wastes are not entering the landfill facility, a Waste Screening
Program has been implemented at the landfill. Waste received at the scalehouse and wastes
taken to the working face are inspected by trained personnel. The facility is only allowed to
receive waste from generated in with the City of Greensboro and Guilford County.
9
City of Greensboro | White Street C&D Landfill – Operations PlanWaste Screening Program

10
16.1 Waste Receiving and Inspection
All vehicles (customers and visitors) must stop at the scalehouse. All refuse containing vehicles
are weighed and their load assessed. All visitors must report in the scalehouse and sign in. The
scale attendant requests from the driver of the refuse containing vehicle a brief description of
the waste to ensure that unacceptable wastes are not allowed in the landfill. The scale attendant
then requests from the driver the following information to document all inspections:
 Date and time
 Source and type of wastes
 Hauling company, vehicle and driver identification
 Net weight of load
The landfill will notify the Division within 24 hours of attempted disposal of any waste the C&D
landfill is not permitted to receive, including waste from outside its service area.
16.2 Waste Screening
Each day, haulers are subject to being screened as part of the waste screening program. A
minimum of one truck must be screened per day. The current waste screening program will
continue to be utilized by the landfill staff for determination of accurate disposal areas and the
prevention of prohibited wastes as described in Rule .542 (e).
1. The scale attendants utilize a computer based random number generator to determine
the vehicles to be screened that day.
2. The scale attendants notify the landfill technician when the incoming loads are five loads
away from the number that has been selected for screening.
3. Once the incoming load has been selected, the scale attendant informs the hauler that
the load will be inspected, collects the name of the waste generator, the origin of the
waste, the type of waste, and the weight of the waste. The truck is then directed to the
correct disposal area.
4. Upon arrival at the disposal site, the waste hauler is directed where to deposit the load
for inspection. The waste will be deposited in an area separate and away from the
working face of the disposal area. The waste hauler then presents the weigh ticket to the
inspector who records the ticket number, waste hauler information, date, and time.
5. The inspector will examine the load. The inspector will verify the waste complies with all
items on the Waste Screening Inspection Form (Form 1, Waste Screening). The
inspector will also include a brief description of the waste on the form.
6. The driver must remain with the waste until is determined by the inspectors that it is
acceptable for disposal. If it deemed acceptable, the driver and truck may be released.
The waste material is then moved to the working face for disposal. The inspection area
is cleaned and prepared to receive another load.
7. If through the normal procedures of the Waste Screening Program or regular daily
operations, a hauler has been identified as routinely bringing prohibited wastes for
disposal, that hauler will be subject to daily screening in addition to the random load(s)
as selected for that day.
City of Greensboro | White Street C&D Landfill – Operations Plan Hazardous Waste Contingency Plan
Any prohibited wastes detected through this program are recorded on the Waste Screening
Inspection Form and the incident is described in detail on the Report of Attempted Disposal
of Hazardous or Prohibited Waste form (Form 2 Report of Attempted Disposal of Hazardous
or Prohibited Materials). If unacceptable wastes are found, the load will be isolated and
secured. The Solid Waste Disposal Manager will then notify the Waste Management
Specialist of NCDEQ within 24 hours of attempted disposal.
All Waste Screening Inspection Forms, hauler information, reports of attempted disposal of
prohibited wastes, and records of disposition of rejected wastes are maintained in the
operating record in the scalehouse. These records are routinely electronically archived and
hard copies are stored and secured in the records storage room in the Operations Building
2503 –B.
17.0 Hazardous Waste Contingency Plan
In the event that identifiable hazardous waste or waste of questionable character is discovered
at the landfill, whether through the waste screening program or normal operations, the
Hazardous Materials Contingency Plan (Appendix C, Attachment 1) shall be instituted
immediately.
18.0 Access Control
Entry to the site is limited to landfill personnel, approved waste haulers, and properly identified
persons whose entry is authorized by the site management and properly logged in. The City
reserves the right to restrict access to the site. The landfill routinely performs public information
tours and educational of the facility for civic groups and local grade schools and universities.
These tours are conducted with a landfill staff member present at all times. Visitors may be
allowed near the active area only when accompanied by one of the landfill staff.
As shown in Figure 2, a sign is posted at the entrance of the landfill stating the facility name,
permit number, operating hours, and prohibited wastes. As shown in Figure 3, there is additional
signage posted periodically throughout the landfill to direct traffic flow and to provide information
on the location of appropriate disposal sites.
The facility is surrounded on the west, southwest, south, southeast and eastern sides by means
of a chain link fence. All gates in this fence network are secured with locks and chains
preventing vehicular access and illegal dumping. As stated in landfill property deeds, the
northern and northwestern property line of the landfill facility is the center of North Buffalo
Creek. This creek, being a natural barrier also prohibits vehicular access and illegal dumping.
19.0 Drainage, Sedimentation and Erosion
Control
The landfill facility has an extensive network of sedimentation and erosion control devices to
restrict sediments being carried from the site. The landfill facility has developed a Storm Water
11
City of Greensboro | White Street C&D Landfill – Operations Plan Water Protection
Pollution and Prevention Plan (SWPPP, Drawing CD-80B) to further manage runoff and protect
the integrity of North Buffalo Creek. Sediment basins also prevent the discharge of pollutants
into the waters of the United States, including wetlands that may violate any requirements of the
Clean Water Act, including but not limited to National Pollutant Discharge Elimination System
(NPDES) requirements. In areas which will not have additional waste placed on them for three
months or more, but where final termination of disposal operations has not occurred, vegetative
cover will be present to prevent on-site erosion. Vegetative cover soil will be capable of
supporting grass and vegetation growth. Drainage channels, benches, and other features will
have appropriate control devices installed. Where needed, down slope drains will be
constructed of 15” corrugated plastic pipe. All devices are routinely inspected and repairs are
made as necessary and as soon as possible after detection.
No solid waste will be disposed of in standing water and surface water will be diverted away
from the active face. In addition, surface water will not be impounded over or in waste.
20.0 Water Protection
The landfill has a comprehensive surface and groundwater monitoring program (reference
Figure 3 on the S&ME WQMP) to provide early detection information to allow for the prevention
of pollution to groundwater. This program is also comprised of a Groundwater Monitoring Plan
prepared by S&ME, project number 1584-98-081 which is included herewith and made a part
thereof and is included in Appendix D.
21.0 Maintenance
21.1 Repair of Security Control Devices
Should the routine inspection process note any deficiencies in any of the security and access
control devices, maintenance and repair will be performed as necessary. Locks, vehicular gates,
and fencing will be replaced if functioning improperly. Warning and information signs will be kept
legible at all times and will be replaced if damaged by inclement weather or vandalism.
21.2 Erosion Damage Repair
Should the routine inspection process note any evidence of erosion in any areas of the final cap
system, maintenance, repair, and reseeding will be performed as necessary and as soon as
possible after detection. Excessive slopes will be flattened if possible by adding clean fill
material. If necessary, erosion control fabrics will be used to expedite re-vegetation of slopes
and to secure topsoil in place.
21.3 Correction of Settlement, Subsidence, and Displacement
Minimum slopes of 5% will be maintained after settlement in order to prevent ponding and allow
for proper drainage while preventing infiltration. If vertical or horizontal displacement occurs due
to differential settlement, cracks will be filled with appropriate material and final cover will be
reestablished.
12
City of Greensboro | White Street C&D Landfill – Operations Plan Benchmarks
21.4 Repair of Run-On/Run-Off Control Structures
All terraces, swales, and perimeter channels will be repaired, cleaned, or realigned to maintain
original conditions and performance. Any culverts, pipe, or other control device that becomes
damaged will be repaired or replaced.
21.5 Leachate Seep Prevention/Repairs
The landfill prevents leachate breakouts by maintaining the proper thickness of intermediate
cover and repairing erosion rills as necessary. In the event of a leachate breakout the landfill
staff would place additional soil cover in the area and re-vegetate.
22.0 Benchmarks
The landfill has a comprehensive horizontal and vertical control benchmark network (Drawing
CD-82B). This network is based on NAD 83 and NAVD 88. In addition to the on-site
benchmarks, the landfill facility has one NCGS control point (57W-200) on site and five points
on the west, south and east sides of the facility.
Figure 4 Typical Benchmark Signage Figure 5 Recordkeeping
23.0 Record Keeping
The City of Greensboro maintains detailed records of all activities relating to the landfill. These
records are kept on site. The records, generated electronically and hard copy are maintained
electronically in the Administration Building and archived on readily accessible media in the
records storage room in the Operations Building (2503 B). The records generated, maintained
and available upon request by the Division are as follows.
1. Waste Screening Inspection Form (Appendix C, Form 1)
2. Report of Attempted Disposal of Hazardous or Prohibited Materials Form (Appendix C,
Form 2)
3. Waste determination records
4. Amounts of waste received
5. Gas Monitoring results
13
City of Greensboro | White Street C&D Landfill – Operations Plan Record Keeping
6. Any demonstration, certification, finding, monitoring, testing, or analytical data required
by Rules .1630 thru .1637.
7. Any monitoring, testing, or analytical data as required by rule .1627.
8. Employee training records
9. Manager’s certifications
10. Landfill specialist certifications
11. Reports of attempts at disposal of prohibited wastes
12. Facility inspections
13. Notation of date and time of cover placement
14. Notation of date of approval and name of Division personnel who approved burning (if
applicable)
15. Approved Operation and Engineering Plan
16. Current permit to construct and permit to operate
17. Approved Monitoring Plan
18. Any cost estimates and financial assurance documentation required by Rule .0546.

14
SOLID WASTE MANAGEMENT FACILITY
FIRE OCCURRENCE NOTIFICATION
NCDEQ Division of Waste Management
Solid Waste Section
Notify the Section verbally within 24 hours and submit written notification within 15 days of the occurrence.
(If additional space is needed, use back of this form.)
NAME OF FACILITY:PERMIT #
DATE AND TIME OF FIRE:@
HOW WAS THE FIRE REPORTED AND BY WHOM:
LIST ACTIONS TAKEN:
WHAT WAS THE CAUSE OF THE FIRE:
DESCRIBE AREA, TYPE, AND AMOUNT OF WASTE INVOLVED:
WHAT COULD HAVE BEEN DONE TO PREVENT THIS FIRE:
DESCRIBE PLAN OF ACTIONS TO PREVENT FUTURE INCIDENTS:
NAME:TITLE:DATE:
***********************************************************************************************************
THIS SECTION TO BE COMPLETED BY SOLID WASTE SECTION REGIONAL STAFF
DATE RECEIVED _________________________________
List any factors not listed that might have contributed to the fire or that might prevent occurrence of future fires:
___________________________________________________________________________________________________________
FOLLOW-UP REQUIRED:
NO PHONE CALL SUBMITTAL MEETING RETURN VISIT BY:____________________ (DATE)
ACTIONS TAKEN OR REQUIRED:
Revised 6/15/2016
City of Greensboro | White Street C&D Landfill – Operations Plan Attachment 1 – Hazardous Materials Contingency Plan

1
Attachment 1 – Hazardous
Materials Contingency Plan

City of Greensboro | White Street C&D Landfill – Operations Plan Attachment 1 Hazardous Materials Contingency Plan
Hazardous Materials Contingency Plan
This plan is developed to meet the requirements of the North Carolina Administrative Code
13B.1626 (1) (f) (iv). The White Street Sanitary Landfill does not accept any liquid or hazardous
waste. Active measures are taken to insure that hazardous materials do not enter the landfill.
These include signage, customer screening, radiation scanning and load inspections.
This plan establishes procedures that must be taken to minimize hazards to human health and
the environment caused by sudden, non-sudden, or unplanned explosion, fire, discovery, or
release of an unknown or hazardous material to the air, soil, surface water, or ground water.
1 Facility Identifications and General Information
Owner/Operator: The City of Greensboro
Department of Environmental Services
Division of Solid Waste Management
White Street Sanitary Landfill
Location: 2503 White Street
Greensboro, North Carolina 27405
Mailing Address: PO Box 3136
Greensboro, NC 27402-3136
Telephone: [phone] (Administration Office)
[phone] (Landfill Operations)
[phone] (Landfill Operations Cell Phone)
1.1 Facility Type
This site is a solid waste management disposal facility comprised of the following operations: (a)
municipal solid waste (MSW) disposal sites (active and closed), (b) construction and demolition
debris (C&D) landfill, (c) yard waste composting facility, (d) heavy equipment maintenance
garage, (e) automated fuel dispensing station, (f) three administrative office buildings, (g)
equipment and material storage facility, (h) two phase landfill gas systems.
The White Street Sanitary Landfill is not a RCRA Hazardous Waste generator or disposer. Any
hazardous materials encounter on this site will be as a result of an attempt to improperly
dispose of materials banned from this site or materials exempt from regulation.
1.2 Personnel Training
Facility personnel are properly instructed in the operation and maintenance of all equipment
used to prevent discharges from the site. Personnel receive training upon employment and
annual refreshers. The Hazardous Materials Contingency Plan is reviewed and updated
annually.
1
City of Greensboro | White Street C&D Landfill – Operations Plan Attachment 1 Emergency Coordinators
2 Emergency Coordinators
Primary Emergency Coordinator Business Phone Cellular
Solid Waste Disposal Manager
112 Cypress St. Greensboro, NC 27405

[phone] [phone]

Secondary Emergency Coordinators Business Phone Cellular
Operations Supervisor 1921 Rankin Mill Rd. Greensboro, NC 27405
[phone] [phone]
Environmental Compliance Specialist 2407 Four Seasons Blvd. Greensboro, NC 27407

[phone] [phone]
Composting Facility Supervisor [phone] [phone]

3 Emergency Phone Numbers
Fire and/or Hazmat 911 or 373-2222
Police 911 or 373-2222
Emergency Medical Service 911
Emergency Management (Greensboro/Guilford Co.) 336-373-2278 or 336-574-4082
Emergency Management Operations (NCDEQ) [phone]
NCDEQ DWM (Winston-Salem Regional Office 336-771-5000
NC Department of Labor – OSHA [phone] or 1-800-625-2267
CHEMTREC [phone]
National Response Center [phone] or 202-267-2675
Medical Services (City of Greensboro) 336-373-2412
Moses Cone Hospital (Emergency Department) 336-832-8040

4 Emergency Response Procedures
In the event that hazardous or suspicious materials are detected at the landfill, the following
steps will be taken:
4.1 Notification
The individual discovering the situation will immediately notify the Administrative Building. The
operator receiving the call will immediately notify the Emergency Coordinator.
2
City of Greensboro | White Street C&D Landfill – Operations Plan Attachment 1 Follow-up
The Emergency Coordinator shall assess the situation and take action as necessary. In the
event of an actual emergency situation, the Emergency Coordinator must immediately take the
following steps:
1. Notify all landfill personnel.
2. Evacuate personnel and customers to a safe location, as appropriate.
3. Require transporter to remain at facility, as appropriate.
4. Implement the appropriate action plan (see appendix).
5. Notify Greensboro Fire Department Hazmat Team if appropriate.
6. Notify NCDEQ DWM, Solid Waste Section.
7. If the Emergency Coordinator has determined that the facility has had a release, fire or
explosion that could threaten human health, or the environment, outside the facility, then
the NCDEQ Emergency Management Center (800-858-0368) and the National
Response Center (800-424-8802) must be notified and the report should include the
following information:
a. Name and telephone number of reporter
b. Name and address of facility
c. Time and type of incident (release, fire, etc.)
d. Name and quantity of material involved
e. The extent of injuries, if any
f. Possible hazards to human health, or the environment, outside the facility
g. Corrective actions taken or planned
5 Follow-up
The Emergency Coordinator will ensure that, after a hazardous materials emergency has
occurred, all recovered waste, contaminated soil and water will be disposed of in accordance
with EPA guidelines.
The Emergency Coordinator will see that all materials used in the containment or cleanup are
replaced in a timely manner.
The Emergency Coordinator will also ensure that an investigation be conducted to determine
the cause of the incident and the steps will be taken to prevent its reoccurrence.
The Emergency Coordinator shall notify NCDEQ within 24 hours of an attempted disposal of
any waste the landfill is not permitted to receive, including waste from outside the area the
landfill is permitted to serve. Within five days of the incident, the Emergency Coordinator must
submit a written report to the NCDEQ, DWM, Solid Waste Section. The report must include the
following:
a. The name, address, and telephone umber of the facility
b. The name, address and telephone number of the transporter
c. The name address and telephone number of the waste generator
d. When the incident took place
3
City of Greensboro | White Street C&D Landfill – Operations Plan Attachment 1 Appendix
e. Who was responsible for responding the incident (Hazmat Team, Environmental
Clean-up contractor, etc.)
f. The response actions taken
g. The extent of human injuries caused by the incident
h. An assessment of harm to both human health and environment
i. The amount of materials recovered and disposed of the incident
j. Additionally, the report should contain documentation of calls of notification to the
state or EPA as appropriate.
k. Note preventative measures, if any, and historical incidents at the site.
6 Appendix
The Emergency Coordinator will ensure that, after a hazardous materials emergency has
occurred, all recovered waste, contaminated soil and water will be disposed of in accordance
with EPA guidelines.
The Emergency Coordinator will see that all materials used in the containment or cleanup are
replaced in a timely manner.
The Emergency Coordinator will also ensure that an investigation be conducted to determine
the cause of the incident and the steps will be taken to prevent its reoccurrence.
The Emergency Coordinator shall notify NCDEQ within 24 hours of an attempted disposal of
any waste the landfill is not permitted to receive, including waste from outside the area the
landfill is permitted to serve. Within five days of the incident, the Emergency Coordinator must
submit a written report to the NCDEQ, DWM, Solid Waste Section. The report must include the
following:
a. The name, address, and telephone umber of the facility
b. The name, address and telephone number of the transporter
c. The name address and telephone number of the waste generator
d. When the incident took place
e. Who was responsible for responding the incident (Hazmat Team, Environmental
Clean-up contractor, etc.)
f. The response actions taken
g. The extent of human injuries caused by the incident
h. An assessment of harm to both human health and environment
i. The amount of materials recovered and disposed of the incident
j. Additionally, the report should contain documentation of calls of notification to the
state or EPA as appropriate.
k. Note preventative measures, if any, and historical incidents at the site.
4
City of Greensboro | White Street C&D Landfill – Permit Amendment Appendix D – Water Quality Monitoring Plan

D D
Appendix D – Water Quality
Monitoring Plan

North Carolina Department of Environment and Natural Resources
Dexter Matthews, Director Division of Waste Management Beverly Eaves Perdue, Governor
Dee Freeman, Secretary

1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.wastenotnc.org
An Equal Opportunity / Affirmative Action Employer - 50 % Recycled \ 10 % Post Consumer Paper
1
May 14, 2009

Ms. Jeryl Covington
City of Greensboro Environmental Services Department
P.O. Box 3136
Greensboro, NC 27402

Re: Approval of Corrective Action Plan (CAP)
White Street Landfill, Phase II, Guilford County, Permit #41-03

Dear Ms. Covington:

The Solid Waste Section has reviewed the June 30, 2008 White Street Landfill Phase II Corrective Action
Plan (CAP) and the April 2009 Revised White Street Landfill Phase II Corrective Action Plan (CAP)
submitted on behalf of the City of Greensboro by S&ME, Inc. Pursuant to 15A NCAC 13B .1636, the
City of Greensboro selected Monitored Natural Attenuation (MNA), Phytoremediation, and maintaining a
consistent contour within Phase II as the remedy to restore groundwater quality and effectively reduce the
groundwater contamination at the facility. The Solid Waste Section approved the selected remedy for the
White Street Landfill, Phase II on June 24, 2008.

The Corrective Action Plan (CAP) proposes implementation of the following activities:
Monitored Natural Attenuation (MNA)
Phytoremediation
Maintaining a consistent contour within Phase II

A comprehensive MNA baseline will be established at the facility consisting of four consecutive quarterly
sampling events. In addition, hybrid poplars and willows will be used in a phytoremediation system by
enhancing the corrective action of the metal thallium and volatile organic compounds impacting
groundwater downgradient from the facility. As a result, the Solid Waste Section hereby approves the
Corrective Action Plan for immediate implementation. The implementation of the approved selected
remedy shall now take place in accordance with 15A NCAC 13B .1637, .0547, and as outlined in the
Corrective Action Plan. If the selected remedy proves to be ineffective, then the contingency plan located
within the Corrective Action Plan shall be implemented. If you have any questions or concerns regarding
this letter, please contact me at 919-508-8500. Thank you for your continued cooperation with this
matter.

Sincerely,
Jaclynne Drummond
Hydrogeologist
Environmental Compliance
Solid Waste Section

1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.wastenotnc.org

An Equal Opportunity / Affirmative Action Employer - 50 % Recycled \ 10 % Post Consumer Paper
2

cc: Connel Ware, S&ME, Inc.
Greg Thomasson, City of Greensboro
Mark Poindexter, Field Operations Supervisor
Jason Watkins, Central District Supervisor
Hugh Jernigan, Environmental Senior Specialist
Ming Tai Chao, Permitting Engineer
Ellen Lorscheider, Planning and Programs Manager
Solid Waste Section Central Files

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g
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2

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9
PQL NCAC 2L
I-
5

I
I
-
1

I
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-
2

I
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-
3

I
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-
4

I
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5

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6

I
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7

I
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7
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I
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3

M
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1
4

std.
BQ
L

1
.
9

B
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L

B
Q
L

B
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L

B
Q
L

B
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N
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N
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B
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B
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5

2
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8
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0
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5

2
.
8
BQ
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B
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5

2
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8
BQ
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B
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L

B
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L

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B
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L

B
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L

B
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L
56
.
2
NI

B
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L

B
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L

B
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L

5

2
.
8
BQ
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
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L
93
NI

B
Q
L

B
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L

B
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L

5

2
.
8
BQ
L

B
Q
L

B
Q
L

B
Q
L

B
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L

B
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L

B
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L
73
NI

B
Q
L

B
Q
L

B
Q
L

5

2
.
8
BQ
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L
82
NI

B
Q
L

B
Q
L

B
Q
L

5

2
.
8
BQ
L

B
Q
L

B
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L

B
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L

B
Q
L

B
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L

B
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L
10
0
NI

B
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L

B
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L

B
Q
L

5

2
.
8
BQ
L

B
Q
L

B
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L

B
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L

B
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L

B
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L

B
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L
63
NI

B
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L

B
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L

B
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L

5

2
.
8
BQ
L

B
Q
L

B
Q
L

B
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L

B
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L

B
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B
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L
90
NI

B
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L

B
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L

B
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L

5

2
.
8
BQ
L

B
Q
L

B
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L

B
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L

B
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L

B
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L

B
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10
NI

B
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L

B
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L

B
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L

5

2
.
8
BQ
L

B
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L

B
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L

B
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L

B
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L

B
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L

B
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L
18
0
NI

B
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L

B
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L

B
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L

5

2
.
8
BQ
L

B
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L

B
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L

B
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B
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B
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B
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B
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N
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B
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5

2
.
8
BQ
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B
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B
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B
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B
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B
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5

2
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8
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B
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B
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B
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N
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B
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5

2
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8
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5

2
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5

2
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8
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20
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5

2
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8
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5

2
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(
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3

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f

9
PQL NCAC 2L
I-
5

I
I
-
1

I
I
-
2

I
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3

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I
-
4

I
I
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5

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6

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-
7

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7
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I
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8

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1
3

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1
4

std.
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B
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L

B
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B
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5

0
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7
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5

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7
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L

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L

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Q
L

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Q
L

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L

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L

5

0
.
7
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L

B
Q
L

B
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L

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L

B
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L

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95
.
4
NI

B
Q
L

B
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L

B
Q
L

5

0
.
7
BQ
L

B
Q
L

B
Q
L

B
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L

B
Q
L

B
Q
L

B
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16
0
NI

B
Q
L

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L

B
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L

5

0
.
7
BQ
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L
66
NI

B
Q
L

B
Q
L

B
Q
L

5

0
.
7
BQ
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L
77
NI

B
Q
L

B
Q
L

B
Q
L

5

0
.
7
BQ
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L
52
NI

B
Q
L

B
Q
L

B
Q
L

5

0
.
7
BQ
L

B
Q
L

B
Q
L

B
Q
L

B
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n

L
i
m
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t
s
An
a
l
y
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l

r
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s
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s

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t
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n

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c
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s
p
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P
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15
A

N
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r
t
h

C
a
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A
d
m
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2
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.
0
2
0
0
,

G
r
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d
w
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Q
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l
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t
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f
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r

C
l
a
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s

G
A

g
r
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d
w
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r
ns

=

n
o

c
o
r
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s
p
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n
d
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g

N
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A
C

2
L

g
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q
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s
t
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No
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a
n
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e
d
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D
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D
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c
h
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f
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L

t
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t
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L
)

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n

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0
0
7
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E

P
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T

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.

1
5
8
4
-
9
8
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8
1
Sa
m
p
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e

L
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a
t
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n
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B
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,

N
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R
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H

C
A
R
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L
I
N
A
NA

=

=

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r
a
n
g
e

c
e
l
l
s

i
n
d
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c
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t
e

t
h
e

r
e
p
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d

c
o
n
c
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n
t
r
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t
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n

e
x
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d
s

t
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e

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C
D
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N
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G
P
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g
r
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n
d
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s
t
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l

c
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s

a
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e
p
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d

i
n

m
i
c
r
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g
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m
s

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r

l
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t
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r

(
µ
/
L
)
.
PQ
L

=
BQ
L

=
NC
A
C

2
L

s
t
d
.
.

=
TA
B
L
E

6
TH
A
L
L
I
U
M
DE
T
E
C
T
I
O
N

A
B
O
V
E

2
L

S
U
M
M
A
R
Y

T
A
B
L
E
PH
A
S
E

I
I

-

W
H
I
T
E

S
T
R
E
E
T

L
A
N
D
F
I
L
L
Pa
g
e

6

o
f

9
Sa
m
p
l
i
n
g

D
a
t
e
PQ
L
NCAC 2L
I
I
-
7
B

I
I
-
9

I
I
-
1
0

I
I
-
1
1

I
I
-
1
2

I
I
-
2
B

I
I
-
1
3

std.
9/
1
3
/
2
0
0
1

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

5

0
.
7
3/
7
/
2
0
0
2

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

5

0
.
7
9/
1
8
/
2
0
0
2

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

5

0
.
7
4/
1
5
/
2
0
0
3

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

5

0
.
7
10
/
1
6
/
2
0
0
3

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

5

0
.
7
3/
2
4
/
2
0
0
4

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

5

0
.
7
9/
2
2
/
2
0
0
4

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

5

0
.
7
2/
1
7
/
2
0
0
5

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

5

0
.
7
5/
1
1
/
2
0
0
5

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

N
I

N
I

5

0
.
7
10
/
1
1
/
2
0
0
5

B
Q
L

N
A

N
A

N
A

N
A

N
I

N
I

5

0
.
7
4/
2
4
/
2
0
0
6

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

N
I

N
I

5

0
.
7
10
/
1
9
/
2
0
0
6

B
Q
L

N
A

N
A

N
A

N
A

N
I

N
I

5

0
.
7
4/
1
2
/
2
0
0
7
1.
8
NA

N
A

N
A

N
A

N
I

N
I

1

0
.
7
7/
1
1
/
2
0
0
7

N
A

N
A

N
A

N
A

N
A
2.
3
BQ
L

1

0
.
7
9/
2
7
/
2
0
0
7

0
.
4
9

J

N
A

N
A

N
A

N
A

N
A

N
A

1

0
.
7
NC
D
E
N
R

D
W
M

c
h
a
n
g
e
d

f
r
o
m

P
Q
L

t
o

S
o
l
i
d

W
a
s
t
e

S
e
c
t
i
o
n

L
i
m
i
t

(
S
W
S
L
)

i
n

2
0
0
7
GR
E
E
N
S
B
O
R
O
,

N
O
R
T
H

C
A
R
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L
I
N
A
TA
B
L
E

7
NE
S

W
E
L
L

D
E
T
E
C
T
S

-

T
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T
R
A
C
H
L
O
R
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E
T
H
E
N
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DE
T
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C
T
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N

A
B
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2
L

S
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M
M
A
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Y

T
A
B
L
E
PH
A
S
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I
I

-

W
H
I
T
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S
T
R
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E
T

L
A
N
D
F
I
L
L
PQ
L

=
BQ
L

=
NC
A
C

2
L

s
t
d
.
.

=
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M
E

P
R
O
J
E
C
T

N
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.

1
5
8
4
-
9
8
-
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8
1
Sa
m
p
l
e

L
o
c
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t
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n
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l

c
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c
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n
t
r
a
t
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n
s

a
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e

r
e
p
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t
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d

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n

m
i
c
r
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g
r
a
m
s

p
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r

l
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t
e
r

(
µ
/
L
)
.
15
A

N
o
r
t
h

C
a
r
o
l
i
n
a

A
d
m
i
n
i
s
t
r
a
t
i
v
e

C
o
d
e

2
L

.
0
2
0
0
,

G
r
o
u
n
d
w
a
t
e
r

Q
u
a
l
i
t
y

S
t
a
n
d
a
r
d
s

f or

C
l
a
s
s

G
A

g ro
u
n
d
w
a
t
e
r
An
a
l
y
t
i
c
a
l

r
e
s
u
l
t
s

i
s

l
e
s
s

t
h
a
n

t
h
e

c
o
r
r
e
s
p
o
n
d
i
n
g

P
Q
L
Me
t
h
o
d
s

P
r
a
c
t
i
c
a
l

Q
u
a
n
t
i
t
a
t
i
o
n

L
i
m
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t
s

=

O
r
a
n
g
e

c
e
l
l
s

i
n
d
i
c
a
t
e

t
h
e

r
e
p
o
r
t
e
d

c
o
n
c
e
n
t
r
a
t
i
o
n

e
x
c
e
e
d
s

t
h
e

N
C
A
C

2
L

g ro
u
n
d
w
a
t
e
r

s
t
a
n
d
a
r
d
.
Pa
g
e

7

o
f

9
Sa
m
p
l
i
n
g

D
a
t
e
PQ
L
NCAC 2L
I
I
-
7
B

I
I
-
9

I
I
-
1
0

I
I
-
1
1

I
I
-
1
2

I
I
-
2
B

I
I
-
1
3

std.
9/
1
3
/
2
0
0
1

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

0
.
0
1
5
3/
7
/
2
0
0
2

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

0
.
0
1
5
9/
1
8
/
2
0
0
2

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

0
.
0
1
5
4/
1
5
/
2
0
0
3

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

0
.
0
1
5
10
/
1
6
/
2
0
0
3

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

0
.
0
1
5
3/
2
4
/
2
0
0
4

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

0
.
0
1
5
9/
2
2
/
2
0
0
4

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

0
.
0
1
5
2/
1
7
/
2
0
0
5

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

0
.
0
1
5
5/
1
1
/
2
0
0
5

B
Q
L
12
BQ
L

B
Q
L

B
Q
L

N
I

N
I

1
0

0
.
0
1
5
4/
2
4
/
2
0
0
6

B
Q
L

B
Q
L

B
Q
L

B
Q
L

B
Q
L

N
I

N
I

1
0

0
.
0
1
5
4/
1
2
/
2
0
0
7

B
Q
L

N
A

N
A

N
A

N
A

N
I

N
I

1

0
.
0
1
5
7/
1
1
/
2
0
0
7

N
A

N
A

N
A

N
A

N
A
3.
2
BQ
L

1

0
.
0
1
5
9/
2
7
/
2
0
0
7

B
Q
L

N
A

N
A

N
A

N
A

N
A

N
A

1

0
.
0
1
5
NC
D
E
N
R

D
W
M

c
h
a
n
g
e
d

f
r
o
m

P
Q
L

t
o

S
o
l
i
d

W
a
s
t
e

S
e
c
t
i
o
n

L
i
m
i
t

(
S
W
S
L
)

i
n

2
0
0
7
S&
M
E

P
R
O
J
E
C
T

N
O
.

1
5
8
4
-
9
8
-
0
8
1
Sa
m
p
l
e

L
o
c
a
t
i
o
n
GR
E
E
N
S
B
O
R
O
,

N
O
R
T
H

C
A
R
O
L
I
N
A
PQ
L

=
BQ
L

=
NC
A
C

2
L

s
t
d
.
.

=
Me
t
h
o
d
s

P
r
a
c
t
i
c
a
l

Q
u
a
n
t
i
t
a
t
i
o
n

L
i
m
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t
s
Al
l

c
o
n
c
e
n
t
r
a
t
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o
n
s

a
r
e

r
e
p
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r
t
e
d

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n

m
i
c
r
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g
r
a
m
s

p
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r

l
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t
e
r

(
µ
/
L
)
.

=

O
r
a
n
g
e

c
e
l
l
s

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n
d
i
c
a
t
e

t
h
e

r
e
p
o
r
t
e
d

c
o
n
c
e
n
t
r
a
t
i
o
n

e
x
c
e
e
d
s

t
h
e

N
C
A
C

2
L

gr
o
u
n
d
w
a
t
e
r

s
t
a
n
d
a
r
d
.
15
A

N
o
r
t
h

C
a
r
o
l
i
n
a

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d
m
i
n
i
s
t
r
a
t
i
v
e

C
o
d
e

2
L

.
0
2
0
0
,

G
r
o
u
n
d
w
a
t
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r

Q
u
a
l
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t
y

S
t
a
n
d
a
r
d
s

f or

C
l
a
s
s

G
A

g ro
u
n
d
w
a
t
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r
An
a
l
y
t
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c
a
l

r
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s
u
l
t
s

i
s

l
e
s
s

t
h
a
n

t
h
e

c
o
r
r
e
s
p
o
n
d
i
n
g

P
Q
L
TA
B
L
E

8
NE
S

W
E
L
L

D
E
T
E
C
T
S

-

V
I
N
Y
L

C
H
L
O
R
I
D
E
DE
T
E
C
T
I
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N

A
B
O
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E

2
L

S
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M
M
A
R
Y

T
A
B
L
E
PH
A
S
E

I
I

-

W
H
I
T
E

S
T
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T

L
A
N
D
F
I
L
L
Pa
g
e

8

o
f

9
Sa
m
p
l
i
n
g

D
a
t
e
PQ
L
NC
A
C

2
L

N
C

D
E
N
R
I
I
-
7
B

I
I
-
9

I
I
-
1
0

I
I
-
1
1

I
I
-
1
2

I
I
-
2
B

I
I
-
1
3

st
d
.
GPS (μ g/L)
9/
1
3
/
2
0
0
1

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

n
s
0.28
3/
7
/
2
0
0
2

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

n
s
0.28
9/
1
8
/
2
0
0
2

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

n
s
0.28
4/
1
5
/
2
0
0
3

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

n
s
0.28
10
/
1
6
/
2
0
0
3

B
Q
L

N
I

N
I

N
I

N
I

N
I

N
I

1
0

n
s
0.28
3/
2
4
/
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8
City of Greensboro | White Street Landfill – Permit AmendmentAttachment D1 – NCDEQ Monitoring Memos

D1
Attachment D1 – NCDEQ
Monitoring Memos

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary

MICHAEL SCOTT
Director
State of North Carolina | Environmental Quality | Waste Management
1646 Mail Service Center | 217 West Jones Street | Raleigh, NC 27699-1646
919 707 8200 T

September 9, 2016

UMEMORANDUM

To: Solid Waste Directors, Public Works Directors, Landfill Operators, and
Landfill Owners

From: The Solid Waste Section

Reference: Guidelines for 14-Day Notification of Groundwater Exceedances Form
Submittal per rule: 15A NCAC 13B .1633(c)(1)

• The 14-day notification form should be submitted whenever a groundwater
protection standard (GWPS) is exceeded for the first time.
o As defined in 13B .1634(g)(h), a GWPS will be either of the following: the 2L
standard (most cases); 2L Interim Maximum Allowable Concentration; a
groundwater protection standard calculated by the SWS; or a site-specific
statistical background level approved by the SWS.

• If a facility is undergoing assessment or corrective action, the 14-day notification
form should be submitted UONLYU when the constituent with the reported
exceedance is not being addressed through assessment or corrective action.

• If a facility plans to conduct a re-sampling event to confirm the initial
exceedance, the 14-day notification form should be submitted UONLYU when the
re-sampling event analytical data confirms the initial exceedance.

Gr
o
u
n
d
w
a
t
e
r

Pr
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t
e
c
t
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n

St
a
n
d
a
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d

Ex
c
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e
d
a
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e
*
Y ES
Is
 Fa
c
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l
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t
y

Cu
r
r
e
n
t
l
y
 in

As
s
e
s
s
m
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t

or
 Co
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Ac
t
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?
No
Is
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 or  
CA
 ad
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s
s
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Co
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 w/ 
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ex
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va
l
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(
s
)
?

No
 14 ‐Day  
No
t
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a
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 STOP
Wi
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ve
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re
s
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 & 
An
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 be

co
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?
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Sa
m
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Co
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P
S

Ex
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d
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e
(
s
)
?
Su
b
m
i
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‐Da
y

No
t
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f
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i
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n
 Fo
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SW
S
NC
D
W
M
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n

14
‐Da
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P
S
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d
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o
w
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[p
e
r
 Ru
l
e
 15
A
 NC
A
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NC DEQ Division of Waste Management - Solid Waste 14-Day Notification of Groundwater
Protection Standard Exceedance(s)
Notice: This form and any information attached to it are "Public Records" as defined in NC General Statute 132-1. As such, these documents are
available for inspection and examination by any person upon request (NC General Statute 132-6).
Instructions:
• Prepare one form for each individually monitored unit.
• Please type or print legibly.
• Attach a notification table with values that attain or exceed applicable groundwater protection standards.
• Send the original signed and sealed form, any tables, and Electronic Data Deliverable to: Compliance Unit, NCDEQ-DWM, Solid Waste Section, 1646 Mail Service Center, Raleigh, NC 27699-1646.
Solid Waste Monitoring Data Submittal Information
Name of entity submitting data (laboratory, consultant, facility owner):
Contact for questions about data formatting. Include data preparer's name, telephone number and E-mail address:
Name: Phone:
E-mail:
Facility name: Facility Address: Facility Permit #
Actual sampling dates (e.g.,
October 20-24, 2006)
Environmental Status: (Check all that apply)
Initial/Background Monitoring Detection Monitoring Assessment Monitoring Corrective Action
Additional Information:
A notification of values exceeding a groundwater protection standard as defined in 15A NCAC 13B .1634(g)(h) is attached. It includes a list of groundwater monitoring points, dates, analytical values, NC 2L groundwater standard, NC Solid Waste GWPS and preliminary analysis of the
cause and significance of any concentration.
A re-sampling event was conducted to confirm the exceedances.
Certification To the best of my knowledge, the information reported and statements made on this data submittal and attachments are true and correct.
Furthermore, I have attached complete notification of any sampling values meeting or exceeding groundwater standards or explosive gas levels, and a preliminary analysis of the cause and significance of concentrations exceeding groundwater standards. I am aware that there are significant penalties for making any false statement, representation, or certification including the possibility of a fine and imprisonment.
Facility Representative Name (Print) Title (Area Code) Telephone Number
Signature
Affix NC Licensed/Professional Geologist or Professional
Engineer Seal
Revised 6/2016
Date
Facility Representative Address
NC PG/PE Firm License Number (if applicable effective May 1, 2009)
Alternate Source Demonstration(s) have been approved for the following constituents with report date:
per rule: 15A NCAC 13B .1633(c)(1)
North Carolina Department of Environment and Natural Resources
Division of Waste Management
Pat McCrory John E. Skvarla, III
Governor Secretary

1646 Mail Service Center, Raleigh, North Carolina 27699-1646 2090 US Highway 70, Swannanoa, North Carolina 28778-82111 Phone: [phone] Phone: [phone]
http://portal.ncdenr.org/web/wm/
An Equal Opportunity / Affirmative Action Employer

1
November 5, 2014

MEMORANDUM

To: Solid Waste Directors, Public Works Directors, Landfill Operators, and Landfill Owners

From: Solid Waste Section

Re: Groundwater, Surface Water, Soil, Sediment, and Landfill Gas Electronic Document Submittal

The Solid Waste Section is continuing its efforts to improve efficiencies in document management. All
groundwater, surface water, soil, sediment, and landfill gas documents submitted to the Solid Waste Section are
stored electronically and are made readily available for the public to view on our webpage. Please remember that
hard copies/paper copies are not required, and should not be submitted. The submittal of these electronic
documents following a consistent electronic document protocol will also assist us in our review. Please follow
these procedures when submitting all groundwater, surface water, soil, sediment, and landfill gas documents to the
Solid Waste Section.

Submittal Method and Formatting
 All files must be in portable document format (pdf) except for Electronic Data Deliverables (EDDs)
unless otherwise specified by the Solid Waste Section. All pdf files should meet these requirements:
o Optical Characteristic Recognition (OCR) applied;
o Minimum of 300 dpi;
o Free of password protections and/or encryptions (applies to EDDs as well);
o Optimized to reduce file size; and
o Please begin using the following naming convention when submitting all electronic files: Permit
Number (00-00)_Date of Document (YYYYMMDD). For example: 00-00_20140101.
 Please submit all files via email or by file transfer protocol (FTP) via email to the appropriate
Hydrogeologist unless otherwise specified by the Solid Waste Section. If the electronic file is greater
than 20 MB, please submit the file via FTP or on a CD. If submitting a CD, please mail the CD to the
appropriate Hydrogeologist. The CD should be labeled with the facility name, permit number, county,
name of document, date of monitoring event (if applicable), and the date of document.
 Please be sure a signed Environmental Monitoring Data Form is submitted as part of the electronic file for
all water quality and landfill gas documents (monitoring, alternate source demonstration, assessment,
investigation, corrective action). This completed form should be the first page of the document before the
cover/title page and should not be submitted as an individual file. Blank forms can be downloaded at
http://www.wastenotnc.org/swhome/EnvMonitoring/NCEnvMonRptForm.pdf

Monitoring Data
Monitoring data documents may include any or all of the following: 1) groundwater and surface water monitoring;
2) soil and sediment, and 3) landfill gas monitoring. In addition to the above procedures, at a minimum, please
include the following:

Groundwater and Surface Water Monitoring
 A copy of the laboratory report(s).
 A copy of the sampling log(s).
 A separate table of detections and exceedances for each monitoring location.

1646 Mail Service Center, Raleigh, North Carolina 27699-1646 2090 US Highway 70, Swannanoa, North Carolina 28778-82111 Phone: [phone] Phone: [phone]
http://portal.ncdenr.org/web/wm/
An Equal Opportunity / Affirmative Action Employer

2
o All analytical results should be reported in micrograms per liter (ug/L) except for field
parameters and specific Monitored Natural Attenuation (MNA) parameters.
o Please also include the laboratory’s method detection limit (MDL) in ug/L, the Solid Waste
Section Limit (SWSL) in ug/L, the appropriate NC regulatory standard in ug/L (2L, 2B,
GWPS, IMAC), and the Federal Maximum Contaminant Level (MCL) in ug/L.
o Please BOLD each exceedance result.
 A separate table of field parameters for each monitoring location.
 An Electronic Data Deliverable (EDD) spreadsheet for each monitoring event submitted in the correct
format. All analytical results should be reported in micrograms per liter (ug/L) except for field
parameters and specific Monitored Natural Attenuation (MNA) parameters. The blank EDD template
can be downloaded at http://www.wastenotnc.org/swhome/enviro_monitoring.asp. Please pay
attention to the formats within the spreadsheet. Any EDD received that is not formatted correctly will
be emailed back to be resubmitted via email within five (5) days.
 A separate groundwater monitoring well construction table.
o Please also include the date the well was drilled, well diameter, total well depth, depth to top
of screened interval (in feet), screened interval (in feet), geology of screened interval, TOC
elevation, ground elevation, groundwater elevation, GPS coordinates (latitude and longitude),
and depth to water (in feet).
 A separate groundwater table with groundwater flow rate(s).
 A recent facility figure that includes labeled groundwater and surface water monitoring locations.
 A groundwater flow map with an arrow(s) indicating flow direction(s), including date the
measurements were taken.

Soil and Sediment Sampling
 A copy of the laboratory report(s).
 A copy of the sampling log(s).
 A separate table of detections and exceedances for each sampling location.
o Please also include the results in micrograms per liter (ug/L), the laboratory’s method
detection limit (MDL) in ug/L, and the appropriate NC regulatory standard (PSRG) in ug/L.
o Please BOLD each exceedance result.
 A separate table of soil and/or sediment characteristics.
 A recent facility figure that includes labeled sampling locations.

Landfill Gas Monitoring
 A blank Landfill Gas Monitoring Data Form can be found within the Landfill Gas Monitoring
Guidance document and can be downloaded at
http://portal.ncdenr.org/c/document_library/get_file?uuid=da699f7e-8c13-4249-9012-
16af8aefdc7b&groupId=38361.
 A separate table of landfill gas detections and exceedances for each monitoring location. Please
BOLD each exceedance result.
 A recent facility figure that includes labeled landfill gas monitoring locations (both permanent and
temporary).

If you have any questions or concerns regarding electronic submittals, please feel free to contact the
Hydrogeologist overseeing your facility. The Solid Waste Section greatly appreciates your assistance on
this matter. Working together, we can continue to provide excellent customer service to you and to the
public.
 Jackie Drummond, Asheville Regional Office, 828-296-4706, [e-mail]
 Ervin Lane, Raleigh Central Office, 919-707-8288, [e-mail]
 Elizabeth Werner, Raleigh Central Office, 919-707-8253, [e-mail]
 Christine Ritter, Raleigh Central Office, 919-707-8254, [e-mail]
 Perry Sugg, Raleigh Central Office, 919-707-8258, [e-mail]

North Carolina Department of Environment and Natural Resources
Dexter Matthews, Director Division of Waste Management Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.wastenotnc.org
An Equal Opportunity / Affirmative Action Employer - 50 % Recycled \ 10 % Post Consumer Paper
June 25, 2010
MEMORANDUM
To: Solid Waste Directors, Landfill Owners/Operators, and North Carolina Certified
Laboratories
From: North Carolina Division of Waste Management, Solid Waste Section
Re: Tetrahydrofuran Analysis at Construction and Demolition Landfills
Based upon historical sampling results, health and environmental concerns, and an ongoing EPA
evaluation of tetrahydrofuran (THF), the Solid Waste Section (Section) is requiring, in
accordance with 15A NCAC 13B .0601, that Construction and Demolition Landfills (CDLFs)
begin analyzing ground and surface water samples collected after January 1, 2011 for THF. The
purpose of this memorandum is to inform CDLF owners and operators and laboratories that are
involved in the collection or analysis of environmental samples of this requirement.
Although the North Carolina Occupational and Environmental Epidemiology Branch previously
established a health based standard for THF, there are currently no established
Maximum Contaminant Levels or 15A NCAC 02L .0202 Standards due to the lack
of historical toxicological data necessary to promulgate regulatory standards. However,
THF analysis is currently required at CDLFs located in several states throughout the U.S. and
has been shown to be a constituent of concern in groundwater at CDLFs for several years. In
addition, THF has been documented as a contaminant associated with CDLF leachate.
Due to the potential health hazards associated with THF and its documented presence at CDLFs,
the Section has determined that CDLFs should begin analyzing ground and surface water
samples for THF to ensure protection of human health and the environment. Although
regulatory standards have not yet been established for THF, its presence in groundwater must be
determined in order to accurately assess the risks at each CDLF and determine if regulatory
standards need to be established. The Section will reevaluate monitoring requirements for THF
in the future after enough data has been collected to determine the extent of THF at C&D
facilities.
Laboratories are advised to contact the Division of Water Quality-Laboratory Section-
Certification Branch prior to initiating THF analysis using Method 8260.
If you have any questions or concerns, please feel free to contact Jaclynne Drummond (919-508-
8500) or Ervin Lane (919-508-8516). Thank you for your continued cooperation with this
matter.
City of Greensboro | White Street C&D Landfill – Permit Amendment Appendix E – Construction Quality Assurance (CQA) Plan

E
Appendix E – Construction
Quality Assurance (CQA) Plan

Construction
Quality Assurance
Plan
White Street C&D Landfill
Permit Renewal
Greensboro, North Carolina
December 2016
Revised May 2017

HDR Engineering, Inc. of the Carolinas
440 S Church Street, Suite 1000, Charlotte, NC 28202-2075 704.338.6700 NC License F0116

City of Greensboro | White Street C&D Landfill – CQA Plan Contents
Contents
Contents ......................................................................................................................................... i
1.0 General .............................................................................................................................. 1
1.1 Introduction ..................................................................................................................... 1
1.2 Definitions Relating to Construction Quality ................................................................... 1
1.3 Parties to Construction Quality Assurance ..................................................................... 2
1.4 Scope of Construction Quality Assurance Plan .............................................................. 4
1.5 Units ............................................................................................................................... 4
1.6 References ..................................................................................................................... 4
1.7 Site and Project Control .................................................................................................. 4
2.0 Low Permeability Soil Cap Construction Quality Assurance .............................................. 7
2.1 Introduction ..................................................................................................................... 7
2.2 Low Permeability Soil Cap .............................................................................................. 7
2.3 Soils Testing ................................................................................................................... 8
2.4 Low Permeability Soil Cap Construction Quality Assurance .......................................... 8
3.0 Topsoil Layer Construction Quality Assurance .................................................................. 9
3.1 Introduction ..................................................................................................................... 9
3.2 Topsoil Layer ................................................................................................................ 10
3.3 Materials Testing .......................................................................................................... 10
3.4 Topsoil Layer Construction Quality Assurance ............................................................. 10
4.0 Surveying Construction Quality Control ........................................................................... 11
4.1 Introduction ................................................................................................................... 11
4.2 Survey Control .............................................................................................................. 11
4.3 Surveying Personnel .................................................................................................... 11
4.4 Precision and Accuracy ................................................................................................ 11
4.5 Lines and Grades ......................................................................................................... 11
4.6 Frequency and Spacing ................................................................................................ 12
4.7 Thickness Measurements ............................................................................................. 12
4.8 Tolerances .................................................................................................................... 13
4.9 Documentation ............................................................................................................. 13
5.0 Construction Quality Assurance Documentation .............................................................. 13
5.1 Documentation ............................................................................................................. 13
5.2 Recordkeeping ............................................................................................................. 13
i
City of Greensboro | White Street C&D Landfill – CQA Plan Contents
5.3 CQA Photographic Reporting Data Sheets .................................................................. 15
5.4 Design and/or Project Technical Specification Changes .............................................. 15
5.5 CQA Progress Reports ................................................................................................. 15
5.6 Signature and Final Report ........................................................................................... 16
5.7 Storage of Records ....................................................................................................... 16

Figures
Figure 1 CQA/CQC Lines of Authority and Communication ......................................................... 3

ii
City of Greensboro | White Street C&D Landfill – CQA Plan General
1.0 General
1.1 Introduction
This Construction Quality Assurance (CQA) Plan (Plan) has been prepared to provide the
Owner, Engineer, and CQA Consultant the means to govern the construction quality and to
satisfy landfill certification requirements under current solid waste management regulations.
More specifically, this Plan addresses the soils components of the closure cap system. The cap
system, as referenced herein, generally consists of a compacted low permeability soil layer and
a topsoil layer. General references to the various components in this Plan as the "cap system" is
intended to be as described herein.
The Plan is divided into the following sections:
• Section 1.0 General
• Section 2.0 Low Permeability Soil Cap Construction Quality Assurance
• Section 3.0 Topsoil Layer Construction Quality Assurance
• Section 4.0 Surveying Construction Quality Control
• Section 5.0 Construction Quality Assurance Documentation
1.2 Definitions Relating to Construction Quality
1.2.1 Construction Quality Assurance (CQA)
In the context of this Plan, CQA is defined as a planned and systematic program employed by
the Owner to assure conformity of the cap system installation with Contract Drawings and the
project specifications. CQA is provided by the CQA Consultant as a representative of the Owner
and is independent from the Contractor and all manufacturers. The CQA program is designed to
provide adequate confidence that items or services meet contractual and regulatory
requirements and will perform satisfactorily in service.
1.2.2 Construction Quality Control (CQC)
Construction Quality Control (CQC) refers to actions taken the Contractor to ensure that the
materials and the workmanship meet the requirements of this Plan and the project
specifications. In the case of the cap system, CQC is provided by the Contractor's CQC.
1.2.3 CQC/CQA Certification Document
At the completion of construction, a certification document will be prepared by the CQA
Consultant and be submitted to State Solid Waste Regulators. The certification report will
include all CQC testing performed by the CQC Consultant and all CQA conformance testing
performed by the CQA Consultant.
1.2.4 Discrepancies Between Documents
The Plan is intended to be a supporting document to improve the overall documentation of the
Work. The Plan is less specific from the project specifications, and conflicts may exist between
the documents. The Contractor is instructed to bring discrepancies to the attention of the
1
City of Greensboro | White Street C&D Landfill – CQA Plan General
Engineer or CQA Consultant for resolution. The Engineer has the sole authority to determine
resolution of discrepancies existing within the Contract Documents. Unless otherwise
determined by the Engineer, the more stringent requirement shall be the controlling resolution.
Reference is made to the project specifications, Section 00700 - General Conditions.
1.3 Parties to Construction Quality Assurance
1.3.1 Description of the Parties
The parties to CQA and QC include the Owner, Project Manager, Engineer, Contractor, CQA
Consultant, soils CQA laboratory, CQC Consultant, and soils CQC laboratory. The lines of
authority and communications between each of the parties involved in the CQA and CQC are
illustrated in Figure 1 (see page 4).
1.3.1.1 OWNER
The Owner is the City of Greensboro (City), who owns and/or is responsible for the facility.
1.3.1.2 PROJECT MANAGER
The Project Manager is the official representative of the Owner. The Project Manager serves as
communications coordinator for the project, initiating the resolution, preconstruction, and
construction meetings outlined in Section 1.7. The Project Manager shall also be responsible for
proper resolution of all quality issues that arise during construction.
1.3.1.3 ENGINEER
The Engineer is responsible for the engineering design, drawings, plans, and project
specifications for the cap system.
1.3.1.4 CONTRACTOR
The Contractor is responsible for the construction of the low permeability soil cap and topsoil
layer. The Contractor is responsible for submittal coordination and the overall CQC on the
project.

2
City of Greensboro | White Street C&D Landfill – CQA Plan General
Figure 1 CQA/CQC Lines of Authority and Communication

1.3.1.5 CONSTRUCTION QUALITY ASSURANCE CONSULTANT
The CQA Consultant is a representative of the Owner and is responsible for observing, testing,
and documenting activities related to the CQC/CQA of the earthworks at the site. The CQA
Consultant is also responsible for issuing a facility certification report, sealed by a Professional
Engineer registered in North Carolina.
1.3.1.6 SOILS CONSTRUCTION QUALITY ASSURANCE LABORATORY
The soils CQA laboratory is a party, independent from the Owner, that is responsible for
conducting geotechnical tests on conformance samples of soils used in the cap system. The
soils CQA laboratory service cannot be provided by any party involved with the Contractor.
1.3.1.7 CONSTRUCTION QUALITY CONTROL CONSULTANT
The CQC Consultant is a representative of the Contractor and is responsible for the earthwork
and low permeability soil cap quality control sampling and testing. The term CQC Consultant
shall be used to designate the Engineer in charge of the QC work. The personnel of the CQC
Consultant also includes QC monitors, who are also located at the site for construction
observation and monitoring. The CQC Consultant is responsible for the timely conveyance of
CQC testing results to the CQA Consultant.
City of
Greensboro -
Design Engineer
(HDR)
NC DEQ
Dept. Solid Waste
Certification
Document
Project Manager
(HDR)
Contractor CQA Soils
Laboratory
CQC Consultant

Subcontractors

CQA Program
CQC Program

CQA Consultant
CQC Soils
Laboratory

3
City of Greensboro | White Street C&D Landfill – CQA Plan General
1.3.1.8 SOILS CONSTRUCTION QUALITY CONTROL LABORATORY
The Soils CQC laboratory is a party, independent from the Contractor, which is responsible for
conducting geotechnical tests on conformance samples of soils used in the cap system.
1.3.2 Qualifications of the Parties
The following qualifications are required of all parties involved with the manufacture, fabrication,
installation, transportation, and CQC/CQA of all materials for the cap system. Where applicable,
these qualifications must be submitted by the Contractor to the Project Manager for review and
approval.
1.3.2.1 CONTRACTOR
Qualifications of the Contractor are specific to the construction contract and independent of this
CQA Plan.
1.3.2.2 CONSTRUCTION QUALITY ASSURANCE CONSULTANT
The CQA Consultant will act as the Owner's CQA Representative and will report to the Project
Manager. The CQA Consultant will perform conformance testing to satisfy the requirements of
this Plan, will observe the CQC work performed by the CQC Consultant, and will prepare the
certification document incorporating both CQA and CQC test data. The CQA Consultant will
have experience in the CQC/CQA aspects of landfill cap system construction and soils testing,
and be familiar with American Society of Testing and Materials (ASTM) and other related
industry standards. The activities of the CQA Consultant will be performed under the
supervision of a registered Professional Engineer.
1.3.2.3 CONSTRUCTION QUALITY CONTROL CONSULTANT
The CQC Consultant will be a party, independent from the Contractor. The CQC Consultant will
be experienced with soils, including low permeability soil caps. The CQC Consultant will satisfy
the requirements of the project specifications and be approved by the Project Manager. The
activities of the CQC Consultant will be performed under the supervision of a registered
Professional Engineer.
1.4 Scope of Construction Quality Assurance Plan
The scope of this Plan includes the CQA of the soils components of the cap system for the
subject facility. The CQA for the selection, evaluation, and placement of the soils is included in
the scope. This document is intended to be used in concert with the CQC requirements
presented in the project specifications.
1.5 Units
In this Plan, all properties and dimensions are expressed in United States units.
1.6 References
The Plan includes references to the most recent version of the test procedures of the ASTM.
1.7 Site and Project Control
To guarantee a high degree of quality during installation, clear, open channels of
communication are essential. To that end, meetings are critical.
4
City of Greensboro | White Street C&D Landfill – CQA Plan General
1.7.1 CQA/CQC Resolution Meeting
Prior to field mobilization by the Contractor, a Resolution Meeting will be held. This meeting will
include all parties then involved, including the Project Manager, the CQA Consultant, the
Engineer, the Contractor, and the CQC Consultant.
The purpose of this meeting is to begin planning for coordination of tasks, anticipate any
problems which might cause difficulties and delays in construction, and, above all, review the
CQA and CQC Plans to all of the parties involved. It is imperative that the rules regarding
testing, repair, etc., be known and accepted by all.
This meeting should include all of the following activities:
• communicate to all parties any relevant documents;
• review critical design details of the project;
• review the site-specific CQA and CQC Plans;
• make any appropriate modifications to the CQA and CQC Plans to ensure that they
specify all testing activities that are necessary;
• reach a consensus on the CQA/CQC quality control procedures, especially on methods
for determining acceptability of the soils;
• review the proposed cap system;
• select testing equipment and review protocols for testing and placement of general
earthwork materials;
• confirm methods for the low permeability soil cap material selection testing, acceptable
zone determinations, and test strip installation; and
• confirm the methods for documenting and reporting, for distributing documents and
reports, and confirm the lines of authority and communication.
The meeting will be documented by the Project Manager and minutes will be transmitted to all
parties.
1.7.2 CQA/CQC Preconstruction Meeting
A Preconstruction Meeting will be held at the site prior to placement of the low permeability soil
cap. At a minimum, the meeting will be attended by the Project Manager, Engineer, the CQA
Consultant, the Contractor, and the CQC Consultant.
Specific topics considered for this meeting include:
• make any appropriate modifications to the CQA and CQC Plans;
• review the responsibilities of each party;
• review lines of authority and communication;
• review methods for documenting and reporting, and for distributing documents and
reports;
• establish protocols for testing;
• establish protocols for handling deficiencies, repairs, and retesting;
• review the time schedule for all operations;
5
City of Greensboro | White Street C&D Landfill – CQA Plan General
• review repair procedures; and
• establish soil stockpiling locations (if any).
The meeting will be documented by the Project Manager and minutes will be transmitted to all
parties. The Resolution Meeting and the Preconstruction Meeting may be held as one meeting
or separate meetings, depending on the direction of the Project Manager.
1.7.3 Daily and Weekly CQA/CQC Progress Meetings
A weekly progress meeting will be held between the Project Manager, the CQA Consultant, the
Contractor, the CQC Consultant, and representatives from any other involved parties. This
meeting will discuss current progress, planned activities for the next week, and any new
business or revisions to the work. The CQA Consultant will log any problems, decisions or
questions arising at this meeting in his daily report. Any matter requiring action which is raised in
this meeting will be reported to the appropriate parties.
A daily meeting will be held between the CQA Consultant, the CQC Consultant, and
representatives from any other involved parties. This meeting will discuss current progress,
planned activities for the next shift, and any new business or revisions to the work. The CQA
Consultant will log any problems, decisions, or questions arising at this meeting in his daily
report. Any matter requiring action which is raised in this meeting will be reported to the
appropriate parties.
Meeting frequency will depend on the schedule of the project and the mutual agreement of all
parties involved.
1.7.4 Program or Work Deficiency Meetings
A special meeting will be held when and if a problem or deficiency is present or likely to occur.
At a minimum, the meeting will be attended by all interested parties, the Contractor, the Project
Manager, and the CQA Consultant. If the problem requires a design modification, the Engineer
should also be present. The purpose of the meeting is to define and resolve the problem or work
deficiency as follows:
• define and discuss the problem or deficiency;
• review alternative solutions; and
• implement an action plan to resolve the problem or deficiency.
The meeting will be documented by the Project Manager and minutes will be transmitted to
affected parties.
6
City of Greensboro | White Street C&D Landfill – CQA Plan Low Permeability Soil Cap Construction Quality Assurance
2.0 Low Permeability Soil Cap Construction
Quality Assurance
2.1 Introduction
This section of the Plan addresses the low permeability soil cap, and outlines the soils CQA
program to be implemented with regard to materials confirmation, laboratory and field
confirmation test requirements, overview and interfacing with the Contractor's CQC Program,
and resolution of problems.
2.2 Low Permeability Soil Cap
2.2.1 Subgrade
The subgrade material below the low permeability soil cap will be prepared by the Contractor
prior to the placement of fill. The CQC Consultant will provide density testing of the pre-fill
subgrade at the frequency specified in the project specifications. The CQA Consultant will
observe the proof roll by the Contractor, review the density test data provided by the CQC
Consultant, and provide verification that the pre-fill subgrade is acceptable. The CQA
Consultant may conduct confirmation density testing as deemed appropriate. The CQA
Consultant will visually examine the surface of the subgrade to verify that any potentially
deleterious materials have been removed.
The subgrade material below the low permeability soil cap is composed of controlled fill and in
situ soils. The Contractor shall place controlled fill as required to cover exposed waste and to fill
depressions in the subgrade in accordance with the project specifications. The CQC Consultant
shall provide testing of the controlled fill material in accordance with the project specifications.
The CQA Consultant will provide confirmation testing of the controlled fill as deemed
appropriate.
2.2.2 Low Permeability Soil Cap Material
The low permeability soil cap shall be placed and compacted in accordance with the project
specifications. The CQC Consultant shall conduct field density and moisture tests at the
frequency presented in the project specifications. The CQA Consultant shall provide
conformance tests at a frequency of approximately 10 percent of the required CQC tests.
Additional CQA conformance testing may be performed at the discretion of the CQA Consultant.
Hydraulic Conductivity, Atterberg Limits, and Percent Fines testing of the low permeability soil
cap material shall be performed by the CQC Consultant in accordance with the project
specifications. Additional CQA conformance testing may be performed at the discretion of the
CQA Consultant.
Thickness measurement shall be conducted in accordance with the project specifications by the
CQC Consultant and observed by the CQA Consultant.
7
City of Greensboro | White Street C&D Landfill – CQA Plan Low Permeability Soil Cap Construction Quality Assurance
2.3 Soils Testing
2.3.1 Test Methods
All testing used to evaluate the suitability or conformance of soils materials will be carried out in
accordance with the project specifications.
2.3.2 Soils Testing Requirements
The soil CQC testing must comply with the minimum frequencies presented in the project
specifications. The frequency of CQA testing required will be determined by the CQA Consultant
in light of the potential variability of materials and the acceptance/failure rate of the CQC testing.
2.4 Low Permeability Soil Cap Construction Quality Assurance
CQA will be performed on low permeability soil cap construction. CQA evaluation will consist of:
(1) monitoring the work and observing the CQC testing; and (2) performing laboratory and field
conformance tests. Laboratory CQA conformance tests will be conducted on samples taken at
the borrow source, stockpile, and during the course of the work prior to construction. Field CQA
conformance tests will be conducted during the course of the work.
2.4.1 Monitoring
The CQA Consultant shall monitor and document the construction of the low permeability soil
cap. Monitoring the construction work for the subgrade and the soil cap includes the following:
• observing CQC testing to determine the water content and other physical properties of
the subgrade and low permeability soil cap during compaction and compilation of the
data;
• monitoring the loose thickness of lifts as placed;
• monitoring the action of the compaction and/or heavy hauling equipment on the
construction surface (i.e., penetration, pumping, cracking. etc.); and
• monitoring the number of passes used to compact each lift.
2.4.2 Construction Quality Assurance Judgmental Testing
During construction, the frequency of conformance testing may be increased at the discretion of
the CQA Consultant when visual observations of construction performance indicate a potential
problem. Additional testing for suspected areas will be considered when:
• the rollers slip during rolling operation;
• the lift thickness is greater than specified;
• the fill material is at an improper moisture content;
• fewer than the specified number of roller passes are made;
• dirt-clogged rollers are used to compact the material;
• the rollers may not have used optimum ballast;
• the fill materials differ substantially from those specified; or
• the degree of compaction is doubtful.
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City of Greensboro | White Street C&D Landfill – CQA Plan Topsoil Layer Construction Quality Assurance
2.4.3 Perforations in Cap
Perforations that must be filled will include, but not be limited to, the following:
• nuclear density test probe locations;
• permeability sampling locations; and/or
• thickness checks.
Unless otherwise noted, or as directed by the Project Manager, all perforations of the subgrade
and low permeability soil cap by probes or sample tubes will be backfilled in accordance with
project specifications. The CQA Consultant will observe and confirm that adequate procedures
are being employed.
2.4.4 Deficiencies
If a defect is discovered in the low permeability soil cap product, the CQC Consultant will
immediately determine the extent and nature of the defect. If the defect is indicated by an
unsatisfactory test result, the CQC Consultant will determine the extent of the deficient area by
additional tests, observations, a review of records, or other appropriate means. If the defect is
related to adverse site conditions, such as overly wet soils or surface desiccation, the CQC
Consultant will define the limits and nature of the defect.
2.4.4.1 NOTIFICATION
After determining the extent and nature of a defect, the CQC Consultant will notify the Project
Manager, the CQA Consultant, and Contractor and schedule appropriate retests when the work
deficiency is corrected. The CQA Consultant shall observe all retests on defects.
2.4.4.2 REPAIRS AND RETESTING
The Contractor will correct the deficiency to the satisfaction of the CQA Consultant. If a project
specification criterion cannot be met, or unusual weather conditions hinder work, then the CQC
Consultant will develop and present to the Project Manager and CQA Consultant suggested
solutions for approval.
All retests recommended by the CQC Consultant must verify that the defect has been corrected
before any additional work is performed by the Contractor in the area of the deficiency. The
CQA Consultant will verify that all installation requirements are met and that all submittals are
provided.
3.0 Topsoil Layer Construction Quality Assurance
3.1 Introduction
This section of the Plan addresses the topsoil layer of the cap system and outlines the CQA
program to be implemented with regard to materials confirmation, laboratory and field test
requirements, overview and interfacing with the Contractor's CQC Program, and resolution of
problems.
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City of Greensboro | White Street C&D Landfill – CQA Plan Topsoil Layer Construction Quality Assurance
3.2 Topsoil Layer
3.2.1 Topsoil Layer Material
The topsoil layer shall be placed in accordance with the project specifications. The CQC
Consultant will provide thickness testing of the material at the frequency specified in the project
specifications.
3.3 Materials Testing
3.3.1 Test Methods
All testing used to evaluate the suitability or conformance of topsoil layer materials will be
carried out in accordance with the project specifications.
3.3.2 Material Testing Requirements
The material CQC testing must comply with the minimum frequencies presented in the project
specifications. The frequency of CQA testing will be determined by the CQA Consultant in light
of the potential variability of the materials and the acceptance/failure rate of the CQC testing.
3.4 Topsoil Layer Construction Quality Assurance
CQA evaluation of the topsoil layer will consist of monitoring the work and observing the CQC
testing.
3.4.1 Monitoring
The CQA Consultant shall monitor and document the construction of the topsoil layer.
Monitoring the construction work for the topsoil layer includes the following:
• verifying material meets specification requirements for topsoil;
• monitor placement of material to ensure that it is accomplished in a manner that does
not damage the low permeability soil cap;
• review CQC Consultant thickness testing results and conduct confirmation thickness
testing as deemed appropriate; and,
• verify that the finished surface is free of stones, sticks, or other material 1 IN or more in
any dimension and suitable for seeding.
3.4.2 Deficiencies
If a defect is discovered in the topsoil layer product, the CQC Consultant will immediately
determine the extent and nature of the defect and report it to the CQA Consultant. If the defect
is indicated by an unsatisfactory test result, the CQC Consultant will determine the extent of the
deficient area by additional tests, observations, a review of records, or other means that the
CQA Consultant deems appropriate.
3.4.2.1 NOTIFICATION
After determining the extent and nature of a defect, the CQC Consultant will notify the Project
Manager and Contractor and schedule appropriate retests when the work deficiency is
corrected. The CQA Consultant shall observe all retests on defects.
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City of Greensboro | White Street C&D Landfill – CQA Plan Surveying Construction Quality Control
3.4.2.2 REPAIRS AND RETESTING
The Contractor will correct the deficiency to the satisfaction of the CQA Consultant. If a project
specification criterion cannot be met, or unusual weather conditions hinder work, then the CQC
Consultant will develop and present to the Project Manager suggested solutions for his
approval.
All retests recommended by the CQC Consultant must verify that the defect has been corrected
before any additional work is performed by the Contractor in the area of the deficiency. The
CQA Consultant will verify that all installation requirements are met and that all submittals are
provided.
4.0 Surveying Construction Quality Control
4.1 Introduction
Surveying of lines and grades is conducted on an ongoing basis during construction of the cap
system. Close CQC of the surveying is absolutely essential to ensure that slopes are properly
constructed. The surveying conducted at the site shall be performed by the Contractor.
4.2 Survey Control
Permanent benchmarks and baseline control points are to be established for the site at
locations convenient for daily tie-in. The vertical and horizontal controls for this benchmark will
be established within normal land surveying standards.
4.3 Surveying Personnel
The Contractor's survey crew will consist of a senior surveyor, and as many surveying CQC
monitors as are required to satisfactorily undertake the requirements for the work. All surveying
CQC Personnel will be experienced in the provision of these services, including detailed and
accurate documentation.
All surveying will be performed under the direct supervision of a registered Professional
Engineer or Licensed Land Surveyor licensed in the state in which the project is located. The
Licensed Land Surveyor may be the senior surveyor.
4.4 Precision and Accuracy
A wide variety of survey equipment is available to meet the requirements of this project. The
survey instruments used for this work should be sufficiently precise and accurate to meet the
needs of the project. All survey instruments should be capable of reading to a precision of 0.01-
foot and with a setting accuracy of 20 seconds (5.6 x 10-3 degrees).
4.5 Lines and Grades
The following surfaces shall be surveyed to verify the lines and grades achieved during
construction. The survey should at least include (as deemed appropriate by the Engineer and
CQA Consultant):
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City of Greensboro | White Street C&D Landfill – CQA Plan Surveying Construction Quality Control
• one or more construction baselines;
• a working grid with a sufficient number of benchmarks;
• surface of the subgrade;
• all existing structures within closure area;
• surface of the low permeability soil cap component;
• surface of the topsoil layer;
• elevations and locations of temporary berms;
• top/toe of all perimeter berms, roads, and channels;
• location of edge of final cover; and
• locations and invert elevations of slope drains.
Laser planes are highly recommended for achieving the correct lines and grades during
construction of each surface.
4.6 Frequency and Spacing
All surveying will be carried out immediately upon completion of a given installation to facilitate
progress and avoid delaying commencement of the next installation. In addition, spot checks, as
determined by the senior surveyor, CQA Consultant, or Project Manager, during construction
may be necessary to assist the Contractor in complying with the required grades.
The following spacings and locations will be provided by the CQC surveyor, as a minimum, for
survey points:
• surfaces with slopes less than 10 percent will be surveyed on a square grid not wider
than 100 feet;
• on slopes greater than 10 percent, a square grid not wider than 100 feet will be used;
however in any case, a line of survey points at the crest, midpoint, and toe of the slope
will be taken; and
• a line of survey points no farther apart than 100 feet will be taken along any slope break
(this will include the inside edge and outside edge of any bench on a slope).
4.7 Thickness Measurements
The CQC surveyor, as a representative of the Contractor, shall obtain top and bottom elevations
of the low permeability soil cap and topsoil layer at a maximum 100-foot grid points and at all
grade break lines. The procedure for obtaining top and bottom elevations shall be agreed to by
the CQA Consultant and Engineer prior to construction. The CQC surveyor shall review the
survey information with the Contractor to ensure that the survey demonstrates compliance with
the project technical specifications. The Contractor is responsible for identifying and reporting to
the CQA Consultant any areas of non-compliance evidenced by the survey, and for repairing
such areas. The CQA Consultant and Contractor shall review the thickness measurements of
the low permeability soil cap component prior to placement of the topsoil layer.
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City of Greensboro | White Street C&D Landfill – CQA Plan Construction Quality Assurance Documentation
4.8 Tolerances
Except for soil cap components where no minus tolerances are acceptable, following is the
maximum tolerance for survey points:
• on surfaces, the maximum tolerances shall be 0.2 foot. This tolerance must be set to the
record elevation of the surface below it and not the design elevation.
4.9 Documentation
All field survey notes will be retained by the senior surveyor. The results from the field surveys
will be documented on a set of Survey Record (As-Built) Drawings by the Contractor for
submittal to the CQA Consultant. The Contractor shall certify to the CQA Consultant and
Engineer that the results of the survey demonstrates compliance with the Contract Documents.
These drawings shall, at a minimum, show the final elevations and locations of all surfaces and
appurtenances surveyed in Subsection 4.5 of this Plan.
5.0 Construction Quality Assurance
Documentation
5.1 Documentation
An effective Plan depends largely on recognition of all construction activities that should be
monitored and on assigning responsibilities for the monitoring of each activity. This is most
effectively accomplished and verified by the documentation of QA activities. The CQA
Consultant will document that all QA requirements have been addressed and satisfied.
This Plan integrates the testing and inspection performed by the CQC Consultant in accordance
with the project specifications with the CQA overview and conformance testing performed by the
CQA Consultant, in accordance with this Plan.
The CQA Consultant will provide the Project Manager with the CQC Consultant's daily and
weekly reports including signed descriptive remarks, data sheets, and logs to verify that all CQC
monitoring activities have been carried out. The CQA Consultant will also provide the Project
Manager with a weekly report summarizing CQA activities and identifying potential QA
problems. The CQA Consultant will also maintain, at the job site, a complete file of plans,
reports, project specifications, a CQA Plan, checklists, test procedures, daily logs, and other
pertinent documents.
5.2 Recordkeeping
The CQC Consultant's reporting procedures will include preparation of a daily report which, at a
minimum, will consist of: a) field notes, including memoranda of meetings and/or discussions
with the Contractor; b) observation logs and testing data sheets; and c) construction problem
and solution data sheets. The daily report must be completed at the end of each CQC
Consultant's shift, prior to leaving the site. This information will be submitted weekly to the CQA
Consultant for review.
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City of Greensboro | White Street C&D Landfill – CQA Plan Construction Quality Assurance Documentation
The CQC Consultant's weekly reports must summarize the major events that occurred during
that week. Critical problems that occur shall be communicated verbally to the Project Manager
or CQA Consultant immediately, as well as being included in the weekly reports. The CQC
Consultant's weekly report must be submitted to the CQA Consultant no later than the Monday
following the week reported.
The CQA Consultant's weekly report must summarize the CQC Consultant's weekly and daily
reports, CQA conformance testing activities, construction problems that occurred, and the
resolution of construction problems. The CQA Consultant's weekly report should identify all
potential or actual compliance problems outstanding. The CQA Consultant's weekly report must
be submitted to the Project Manager on the Wednesday following the week reported.
5.2.1 Memorandum of Discussion with CQC Consultant
A report will be prepared summarizing each discussion between the CQA Consultant. At a
minimum, the report will include the following information:
• date, project name, location, and other identification;
• name of parties to discussion at the time;
• relevant subject matter or issues;
• activities planned and schedule; and
• signature of the CQA Consultant.
5.2.2 CQA Observation Logs and Testing Data Sheets
CQA observation logs and conformance testing data sheets will be prepared by the CQA
Consultant on a weekly basis. At a minimum, these logs and data sheets will include the
following information:
• an identifying sheet number for cross-referencing and document control;
• date, project name, location, and other identification;
• a reduced-scale Site Plan showing all proposed work areas and test locations;
• descriptions and locations of ongoing construction;
• descriptions and specific locations of areas, or units, of work being tested and/or
observed and documented;
• locations where tests and samples were taken;
• a summary of test results;
• calibrations or recalibrations of test equipment, and actions taken as a result of
recalibration;
• off-site materials received, including quality verification documentation;
• decisions made regarding acceptance of units of work, and/or corrective actions to be
taken in instances of substandard quality; and
• the CQA Consultant's signature.
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City of Greensboro | White Street C&D Landfill – CQA Plan Construction Quality Assurance Documentation
5.2.3 CQA Construction Problem and Solution Data Sheets
CQA sheets describing special construction situations will be cross-referenced with specific
CQA observation logs and testing data sheets, and must include the following information,
where available:
• an identifying sheet number for cross-referencing and document control;
• a detailed description of the situation or deficiency;
• the location and probable cause of the situation or deficiency;
• how and when the situation or deficiency was found or located;
• documentation of the response to the situation or deficiency;
• final results of any responses;
• any measures taken to prevent a similar situation from occurring in the future; and
• the signatures of the CQA Consultant the Project Manager, indicating concurrence, if
required by this Plan.
5.3 CQA Photographic Reporting Data Sheets
Photographic reporting data sheets, where used, will be cross-referenced with CQA observation
logs and testing data sheets and/or CQA construction problem and solution data sheets.
Photographs shall be taken at regular intervals during the construction process and in all areas
deemed critical.
These photographs will serve as a pictorial record of work progress, problems, and mitigation
activities. The basic file will contain color prints; digital copies will be stored in a separate file in
chronological order. These records will be presented to the Project Manager upon completion of
the project.
In lieu of photographic documentation, videotaping may be used to record work progress,
problems, and mitigation activities. The Project Manager may require that a portion of the
documentation be recorded by photographic means in conjunction with videotaping.
5.4 Design and/or Project Technical Specification Changes
Design and/or project specification changes may be required during construction. In such cases,
the CQA Consultant will notify the Project Manager and the Engineer. The Project Manager will
then notify the appropriate agency, if necessary.
Design and/or project specification changes will be made only with the written agreement of the
Project Manager and the Engineer, and will take the form of an addendum to the project
specifications. All design changes shall include a detail (if necessary) and state which detail it
replaces in the plans.
5.5 CQA Progress Reports
The CQA Consultant will prepare a summary progress report each week, or at time intervals
established at the pre-construction meeting. As a minimum, this report will include the following
information;
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City of Greensboro | White Street C&D Landfill – CQA Plan Construction Quality Assurance Documentation
• a unique identifying sheet number for cross-referencing and document control;
• the date, project name, location, and other information;
• a summary of work activities during progress reporting period;
• a summary of construction situations, deficiencies, and/or defects occurring during the
progress reporting period; and
• summary of all test results, failures and retests, and signature of the CQA Consultant.
5.6 Signature and Final Report
At the completion of each major construction activity at the Landfill, the CQA Consultant will
certify all required forms, observation logs, field and laboratory testing data sheets including
sample location plans, construction problems, and solution data sheets. The CQA Consultant
will also provide a final report, which will certify that the work has been performed in compliance
with the plans and project technical specifications, and that the supporting documents provide
the necessary information.
The CQA Consultant will also provide summaries of all the data listed above with the report. The
Record Drawings will include scale drawings depicting the location of the construction and
details pertaining to the extent of construction (e.g., depths, plan dimensions, elevations, soil
component thicknesses, etc.). All surveying and base maps required for development of the
Record Drawings will be done by the Construction surveyor. These documents will be certified
by the Contractor and CQC Consultant and delivered to the CQA Consultant and included as
part of the CQA documentation (Certification) report.
It may be necessary to prepare interim certifications, as allowed by the regulatory agency to
expedite completion and review.
5.7 Storage of Records
All handwritten data sheet originals, especially those containing signatures, will be stored by the
Project Manager in a safe repository on site. Other reports may be stored by any standard
method which will allow for easy access. All written documents will become property of the
Owner.
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City of Greensboro | White Street C&D Landfill – Permit Amendment Appendix F – Closure/Post-Closure Plans

F
Appendix F – Closure/Post-
Closure Plans

Closure/Post-
Closure Plan
White Street C&D Landfill
Permit Renewal
Greensboro, North Carolina
December 2016
Revised May 2017

HDR Engineering, Inc. of the Carolinas
440 S Church Street, Suite 1000, Charlotte, NC 28202-2075 704.338.6700 NC License F0116

City of Greensboro | White Street C&D Landfill – Closure/Post-Closure Plan Contents
Contents
Contents ......................................................................................................................................... i
1.0 Closure Plan ....................................................................................................................... 1
1.1 Cap System Background ................................................................................................ 1
1.2 Cap System Design ........................................................................................................ 1
1.3 Final Contour Requirements ........................................................................................... 2
1.4 Cap System Material Requirements ............................................................................... 2
1.5 Erosion Control Measures .............................................................................................. 2
1.6 Settlement Subsidence and Displacement ..................................................................... 2
1.7 Schedule for Closure ...................................................................................................... 3
1.8 Notice of Closure and Date of Final Waste Acceptance ................................................. 3
1.9 Closure Verification ........................................................................................................ 3
1.10 Cost Estimate of Closure Activities ................................................................................. 3
2.0 Post-Closure Plan .............................................................................................................. 4
2.1 Introduction ..................................................................................................................... 4
2.2 Post-Closure Contact ..................................................................................................... 4
2.3 Description of Use .......................................................................................................... 4
2.4 Maintenance ................................................................................................................... 4
2.5 Monitoring Plan ............................................................................................................... 5
2.6 Engineering Certification ................................................................................................ 6
2.7 Cost Estimate of Post Closure Care Activities ................................................................ 6

Tables
Table 1 Cap System Requirements .............................................................................................. 2
Table 2 Post Closure Inspection Frequencies .............................................................................. 5

Attachments
Attachment F1 – Closure/Post-Closure Cost Estimate
Attachment F2 – Gas Extraction Well Detail

i
City of Greensboro | White Street C&D Landfill – Closure/Post-Closure Plan Closure Plan
1.0 Closure Plan
1.1 Cap System Background
This closure plan is in accordance with the State Solid Waste Management Rule 0.547(4) for
the White Street C&D Landfill. The final cap system, in accordance with Rule .1627(c)(1),
consists of an 18-inch infiltration layer overlain by a six inch erosion layer. The 65-acre C&DLF
footprint was permitted in 1997 on top of the closed unlined Phase II MSW landfill. The City
closed an 8-acre area of the cap which was approved by North Carolina Department of
Environmental Quality (NCDEQ) on February 17, 2014. A second closure of approximately 26
acres was performed and approved by NCDEQ on September 2, 2015. The remaining 31 acres
are currently being filled.
1.2 Cap System Design
Compacted soil liners will be incorporated in the cap system design to provide protection
throughout the 30-year post-closure period. The system will consist of two layers (bottom up):
the compacted soil liner and the erosion layer. The compacted soil liner forms a composite
barrier designed to reduce infiltration into the Landfill, thus minimizing leachate and the potential
for groundwater contamination. The erosion layer is designed to sustain vegetation and
minimize erosion.
The landfill may use on- or off-site borrow material for the compacted soil layer and erosion
layer. The compacted soil liner will consist of no less than 18 inches of soil having permeability
less than or equal to soils underlying the landfill or no greater than 1.0 x 10-5 cm/sec, whichever
is less. In order to assure that the material meets the permeability criteria, the soil will be tested
prior to use and during placement. It is anticipated that the upper 12 inches of the intermediate
cover will be suitable for compaction and incorporation into the compacted soil layer.
Construction methods for the compacted soil liner shall be based upon the type and quality of
the borrow source and shall be verified in the field by constructing test pad(s). A professional
engineer shall certify that the compacted soil liner installation conforms to the plans approved by
NCDEQ Division of Waste Management.
The erosion layer will consist of no less than six inches of earthen material capable of sustaining
native plant growth. It is anticipated that this layer will consist of suitable on-site or off-site
borrow material.
The materials of the erosion layer will be selected considering soil type, nutrient levels, pH,
erodibility, sideslope drainage, and other factors. The vegetation will be selected based upon
the following characteristics.
• Species of grasses which are locally adapted and resistant to drought or temperature
extremes.
• Having roots which will not disrupt the compacted soil liner.
• Ability to thrive in low nutrient soil and develop a good stand to resist erosion.
• Survive and function with little or no maintenance.
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City of Greensboro | White Street C&D Landfill – Closure/Post-Closure Plan Closure Plan
All cover material will be free of putrescible material, solid waste, vegetation (prior to
placement), rocks, construction debris, frozen soil, and other deleterious materials.
The cap will have a gas venting system that will minimize the build up of pressure being exerted
on the low permeability barrier. The system may consist of vertical wells, horizontal wells, or a
permeable layer beneath the barrier layer that will allow pressures to vent to either the
atmosphere or to a collection system. The spacing of the wells shall be one well per acre. A
lower frequency of wells may be acceptable if it can be demonstrated to control emissions.
1.3 Final Contour Requirements
The final contour requirements for closure are shown on the Drawing C-02. These contours
represent the top of the intermediate cover layer.
The landfill is designed to have minimum top slopes of five percent and side slopes of 4H:1V.
Final contours have been established to allow the landfill’s surface water to drain off the final
cover while limiting erosion potential and maintaining post settlement slopes greater than five
percent. A system of sideslope diversion channels, slope drains, and perimeter channels are
designed to convey the runoff to one of seven adjacent sedimentation basins.
1.4 Cap System Material Requirements
Based on 18 inches of compacted soil liner placed over the areas that require final closure,
75,000 CY of compacted soil will be required for the first layer of the cap system. A minimum of
25,000 CY will be required for the erosion layer. The following table summarizes the cap system
requirements for White Street C&D Landfill.
Table 1 Cap System Requirements
Cap System Requirements
18-inch Compacted Soil Liner 75,000 CY
6-inch Erosion Layer 25,000 CY

1.5 Erosion Control Measures
Vegetation will be established once the final grades of the erosion layer are complete to prevent
erosion of the final cover. The sedimentation basins were designed to control the 24-hour 25-
year storm event.
1.6 Settlement Subsidence and Displacement
Landfill compaction methods, which include the use of compaction equipment to spread and
compact in layers, combined with an adequate number of passes over each layer of waste, will
be utilized to reduce voids and minimize differential settlement. Proper placement of weekly,
intermediate, and final cover will reduce the moisture content of the waste prior to site closure
and further reduce settlement. Final slopes of the landfill have been developed to allow for this
anticipated subsidence so that long-term positive drainage of the fill will not be hindered.
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City of Greensboro | White Street C&D Landfill – Closure/Post-Closure Plan Closure Plan
1.7 Schedule for Closure
According to Rule .0543(c)(5), closure is required to begin either 30 days after the final known
receipt of waste, 30 days after a 10 acre area or greater is within 15 feet of final design grades
or within a year of the most recent receipt of waste. The City of Greensboro will request an
extension from the NCDEQ Division of Waste Management to begin closure activities no later
than 30 days after the known final receipt of waste in accordance with Rule .0543(c)(5).
Closure activities will be completed within 180 days of the start of closure unless an extension
has been requested and received in accordance with Rule .0543(c)(6).
1.8 Notice of Closure and Date of Final Waste Acceptance
A sign indicating the anticipated date of closure and the date of final waste acceptance will be
conspicuously posted at the facility at least 30 days in advance. Prior to beginning closure of the
unit or portions thereof, the NCDEQ Department of Solid Waste Management will be notified
that a notice of intent to close has been placed in the operating record.
1.9 Closure Verification
The following procedures will be implemented following closure.
• A Construction Quality Assurance (CQA) report shall be submitted to the NCDEQ
Division of Solid Waste Management. This CQA report shall describe the observations
and tests used before, during, and upon completion of construction to ensure that the
construction materials meet the cap design specifications and the construction and
certification requirements. The CQA report shall contain as-built drawings.
• A signed certification from an independent registered professional engineer verifying that
closure has been completed in accordance with the closure plan will be submitted to the
NCDEQ Division of Waste Management and a copy will be placed in the operating
record.
• Within 90 days, a survey plat prepared by a professional land surveyor registered by the
State, indicating the location and dimensions of landfill disposal areas, will be recorded
in the RMC office.
• A notation shall be recorded on the deed notifying any potential purchaser of the
property that the land has been used as a solid waste management unit and that future
use is restricted under Paragraph (8) of Rule .0543(c). A copy of the deed notation as
recorded shall be filed with the operating record.
1.10 Cost Estimate of Closure Activities
The cost estimate of closure activities is provided in Appendix F1. The estimate is in 2016
dollars and will be updated in the next financial assurance cycle. The cost estimate is subject to
change prior to the closure of the landfill and as the closure design is finalized.

3
City of Greensboro | White Street C&D Landfill – Closure/Post-Closure Plan Post-Closure Plan
2.0 Post-Closure Plan
2.1 Introduction
This Post-Closure Plan has been developed to outline steps to be taken to ensure the
environmental soundness of the White Street C&D Landfill during its post-closure care period.
The post-closure care period will last at least 30 years after closure completion and at a
minimum will consist of the following.
• Maintaining integrity and effectiveness of final cover system.
• Performing groundwater and surface water monitoring.
• Maintaining and operating a gas monitoring system.
• Maintaining run-on/run-off controls.
No wastes will remain exposed after closure of the unit; the total area of the unit is 135 acres.
Access to the closed site by the public will be restricted. Any proposed use will be evaluated to
determine its potential for posing a significant health hazard. The Phase II MSW Landfill was
closed in 1998. The 90 acre C&D landfill portion of the Phase II currently consists of 59 closed
acres and 31 active acres.
2.2 Post-Closure Contact
All correspondence and questions concerning the post-closure care of the unit should be
directed to:
Solid Waste Disposal Manager
[phone]
2503 White Street
Greensboro, NC 27405
2.3 Description of Use
After the unit is officially closed in accordance with the Closure Plan, the area will be allowed to
return to a natural vegetative state. The City will maintain control of the property and prevent
public access to it during the post-closure period.
There will be an access road on the cap to allow proper maintenance during post-closure. Final
location of the access will be determined as a part of operations and Closure Plan.
2.4 Maintenance
2.4.1 Repair of Security Control Devices
All security control devices will be inspected and maintained as necessary to ensure access to
the site is controlled. Locks, vehicular gates, and fencing will be replaced if functioning
improperly. Warning signs will be kept legible at all times and will be replaced if damaged by
inclement weather or vandalism.
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City of Greensboro | White Street C&D Landfill – Closure/Post-Closure Plan Post-Closure Plan
2.4.2 Erosion Damage Repair
If erosion of the final cover occurs during post-closure, the affected area will be repaired and re-
seeded as necessary. Excessive slopes will be flattened if possible by adding clean fill material.
If necessary, erosion control fabrics will be used to expedite rapid revegetation of slopes and to
secure topsoil in place. Rough surfaces, which cause isolated erosion areas will be smooth and
re-seeded as necessary.
2.4.3 Correction of Settlement, Subsidence, and Displacement
Minimum slopes of five percent will be maintained in order to prevent ponding and allow for
proper drainage without infiltration. If vertical or horizontal displacement occurs due to
differential settlement, cracks will be filled with appropriate material and final cover will be
reestablished.
2.4.4 Repair of Run-On/Run-Off Control Structures
All side slope terraces, ditches, and perimeter channels will be repaired, cleaned or realigned in
order to maintain original condition. Any culverts that are damaged will be replaced.
2.4.5 Groundwater/Gas Monitoring System
Groundwater wells will be inspected regularly (at the time of sampling) to ensure integrity.
Persons inspecting a well should look for signs of well tampering, cracking or degradation, and
determine whether the well needs to be replaced. If the decision is made to replace and
abandon a well, the replacement well should be installed 5 to 10 feet from the abandoned well
in accordance with previous well specifications. Well abandonment should be accomplished by
pulling the casing out and grouting the hole.
2.5 Monitoring Plan
The closed unit shall be monitored for 30 years. A series of inspections shall be scheduled to
ensure the integrity and effectiveness of the cap system, storm water control system,
groundwater monitoring system, gas collection system, and to protect human health and the
environment.
2.5.1 Inspection Frequencies
Inspections to be conducted during the post-closure care period will occur regularly as follows:
Table 2 Post Closure Inspection Frequencies
Post-Closure Inspection Frequencies
Inspection Activity Years 1-3 Years 4-30
Security Control Devices Quarterly Quarterly Cover Drainage System Functioning Quarterly Semiannually
Groundwater Monitoring System Semiannually Semiannually Erosion Damage Quarterly Semiannually
Cover Settlement, Subsidence, and Displacement Quarterly Semiannually
Vegetative Cover Condition Quarterly Semiannually Stormwater Control System Quarterly Semiannually
Benchmark Integrity Annually Annually

5
City of Greensboro | White Street C&D Landfill – Closure/Post-Closure Plan Post-Closure Plan
2.5.2 Quarterly Inspections
Quarterly inspections of the closed site will include examination of the security control devices
for signs of deterioration or vandalism to ensure access to the site is limited to authorized
persons.
2.5.3 Semiannual Inspections
Semiannual inspections of the site during the post-closure period will be conducted by the
Owner or Owner’s representative with attention paid to the integrity of the final cover system.
This includes inspection for erosion damage, a good stand of vegetative cover, and cover
settlement, subsidence, and displacement. Drainage ditches will be cleared of litter and debris,
benchmark integrity will be noted and maintained as well as the integrity of the groundwater and
gas monitoring systems.
Groundwater monitoring will continue on a regular basis throughout the post-closure care
period. The parameters chosen for analysis will be no less than the requirements of regulatory
agencies. Groundwater monitoring wells will be inspected in accordance with the post-closure
inspection protocol. A report of findings will be made to the responsible party via the Post-
Closure Inspection Checklist, including any recommendations for actions necessary to ensure
the site continues to meet the closure performance standard. The engineer will also receive
copies of the quarterly inspection reports and respond to any comments that demand immediate
attention.
2.6 Engineering Certification
Based on the monitoring reports and semiannual site visits, annual certifications by the owner or
owner’s representative will be placed in the operating record. They will certify that the post
closure plan is being followed, noting discrepancies along with the corrective actions
undertaken. At the end of the post-closure period, the individual certifications will be compiled
into a final document and forwarded to NCDEQ.
2.7 Cost Estimate of Post Closure Care Activities
The cost estimate of post-closure care activities is provided in Appendix F1. The estimate is in
2016 dollars and will be updated in the next financial assurance cycle.

6
City of Greensboro White Street C&D Landfill – Closure/Post-Closure Plan Attachment F1 – Closure/Post-Closure Cost Estimate

F1
Attachment F1 –
Closure/Post-Closure Cost Estimate

City of Greensboro, NC
9-Mar-17
Below is a summary of what has been reported for certain amounts in the Financial Assurance Test for Greensboro, since FY2012.
1) Reported for "potential" assessment and corrective action:
Inflation
Factor Reported
FY 16 Used On Line
$2,118,712 Other: Assessment and Corrective Action - Permit 41 - 12
+$2,118,712 1.00%Other: Assessment and Corrective Action - Permit 41 - 03
$4,237,424
FY 15
$2,097,735 Other: Assessment and Corrective Action - Permit 41 - 12
+$2,097,735 1.40%Other: Assessment and Corrective Action - Permit 41 - 03
$4,195,470
FY 14
$2,068,772 Other: Assessment and Corrective Action - Permit 41 - 12
+$2,068,772 1.50%Other: Assessment and Corrective Action - Permit 41 - 03
$4,137,544
FY 13
$2,038,199 Other: Assessment and Corrective Action - Permit 41 - 12
+$2,038,199 1.80%Other: Assessment and Corrective Action - Permit 41 - 03
$4,076,398
FY 12
$2,002,160 Other: Assessment and Corrective Action - Permit 41 - 12
+$2,002,160 Other: Assessment and Corrective Action - Permit 41 - 03
$4,004,320
2) Reported for Estimated groundwater remediation - Phase II in addition to above amounts:
FY 16 $1,567,941 MSWLF under 15A NCAC 13B Section 1600; however also broken out at top of Financial Assurance Form that was submitted
FY15 $1,689,121 MSWLF under 15A NCAC 13B Section 1600; however also broken out at top of Financial Assurance Form that was submitted
FY14 $1,797,521 MSWLF under 15A NCAC 13B Section 1600; however also broken out at top of Financial Assurance Form that was submitted
FY13 2,113,790$ MSWLF under 15A NCAC 13B Section 1600; however also broken out at top of Financial Assurance Form that was submitted
FY12 2,157,660$ MSWLF under 15A NCAC 13B Section 1600; however also broken out at top of Financial Assurance Form that was submitted
Note: The same inlation factors were used for the estimated groundwater remediation costs, as noted above, however, amounts are declining due to
tasks being completed since FY2012, which was considered to be the start of Year 1 of the total 30 year
compliance period.
City of Greensboro | White Street C&D Landfill – Closure/Post-Closure Plan Attachment F2 – Gas Extraction Well Detail

F2
Attachment F2 – Gas
Extraction Well Detail

City of Greensboro | White Street C&D Landfill – Permit Amendment Appendix G – Landfill Gas Monitoring Plan

G
Appendix G – Landfill Gas
Monitoring Plan

Landfill Gas
Monitoring Plan
White Street C&D Landfill
Permit Renewal
Greensboro, North Carolina
May 2017

HDR Engineering, Inc. of the Carolinas 440 S Church Street, Suite 1000, Charlotte, NC 28202-2075 704.338.6700
NC License F0116

City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Contents
Contents
Contents ......................................................................................................................................... i
1.0 Introduction ........................................................................................................................ 1
2.0 Background Information ..................................................................................................... 1
2.1 General ........................................................................................................................... 1
3.0 Landfill Gas Overview & Regulatory Action Levels ............................................................ 1
4.0 Landfill Gas Monitoring ...................................................................................................... 3
4.1 Proposed Landfill Gas Monitoring Procedure ................................................................. 3
4.2 Schedule for Installation of Monitoring Elements ........................................................... 6
4.3 Maintenance and Calibration of Monitoring Elements .................................................... 6
5.0 Contingency Plan ............................................................................................................... 7
5.1 Contingency Plan Guidelines ......................................................................................... 7
5.2 Contingency Plan - On-site Structures ........................................................................... 8
5.3 Contingency Plan - Facility Property Boundary .............................................................. 9
6.0 Safety ............................................................................................................................... 10

Tables
Table 1 Compliance Levels for Methane ...................................................................................... 2
Table 2 Compliance Levels for Hydrogen Sulfide ......................................................................... 2
Table 3 Contingency Plan Contacts .............................................................................................. 8

Figures
Figure 1 Drawing CD-79B Gas Monitoring Wells .......................................................................... 4
Figure 2 Typical Methane Probe Construction .............................................................................. 5

Attachments
Attachment 1 – Field Data Form

i
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Introduction
1.0 Introduction
The purpose of this Landfill Gas Monitoring Plan (LGMP) is to provide a management practice
for the monitoring and control of landfill gas generated by the White Street Construction and
Demolition Debris (C&D) Landfill.
Following approval of this LGMP by the North Carolina Department of Environmental Quality
(NCDEQ) Division of Waste Management (DWM), a routine methane monitoring program will be
implemented at the landfill. Once final closure of the unit is complete, the monitoring program
will continue in accordance with NC regulation, 15A NCAC 13B .0543 (e)(1)(C). Following
approval, this plan will be placed in the landfill operating record and shall remain open for
revisions throughout the active life of the landfill, as well as after landfill closure is complete. All
changes to this plan will be submitted to NCDEQ DWM as they are implemented.
2.0 Background Information
2.1 General
The White Street Landfill is located off White Street approximately five miles northwest of the
City of Greensboro, North Carolina (the City) and is operated under North Carolina NCDEQ
DWM Permit No. 4103-CDLF-1998. The facility consists of three major units: the closed Phase I
unit, the active Phase II C&D unit, which is on top of the closed Phase II MSW unit, and the
Phase III MSW unit which is currently active. The closed Phase II MSW unit is unlined and is
approximately 135 acres. The Phase II C&D landfill area occupies approximately 90 acres.
Land use to the east and north of the Phase II C&D landfill is primarily residential along with
some light industrial use along Rankin Mill Road. To the west is the closed Phase I landfill, and
to the south is the active Phase III MSW landfill.
3.0 Landfill Gas Overview & Regulatory Action
Levels
One of the byproducts of landfilling municipal solid waste is landfill gas which is generated by
the anaerobic decomposition of waste within the landfill. Landfill gas typically consists of
methane (CH4) and carbon dioxide (CO2), with trace amounts of oxygen (O2), water (H2O),
nitrogen (N2), hydrogen sulfide (H2S), and other gases. The amount and rate of generation of
landfill gas is affected by several factors, including the following.
• Total refuse tonnage in-place.
• Moisture content of the refuse.
• Age of the refuse.
• Organic composition and pH value of the refuse.
• Method and degree of compaction of the refuse.
• Type and amount of cover material used.
1
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Landfill Gas Overview & Regulatory Action Levels
The concentration of the landfill gas varies according to site-specific conditions; however, landfill
gas compositions of 30-53 percent methane (CH4) and 34-51 percent carbon dioxide (CO2) are
common.
A byproduct of landfilling C&D waste is hydrogen sulfide gas which is generated by the
anaerobic decomposition of waste within the landfill. The higher concentrations of hydrogen
sulfide are believed to be associated with the gypsum board component (e.g. wallboard) present
in C&D material. The combination of gypsum, organic material, moisture and anaerobic
conditions present in C&D landfills is believed to provide a favorable mixture and environment
for bacteria to produce hydrogen sulfide gas.
C&D landfill owners and operators must insure that the concentration of methane gas or other
explosive gases generated by the facility does not exceed 25 percent of the lower explosive limit
at the facility boundary, in on-site facility structures (excluding gas control or recovery system
components) and the facility does not release methane gas or other explosive gases in any
concentration that can be detected in offsite structures per 15A NCAC 13B .0544 (d).
Landfill gas can travel in all directions, taking the path of least resistance. Landfill gas moves
from areas of higher concentrations to areas of lower concentrations (diffusion), or from higher
gas pressure zones to lower gas pressure zones (convection). Subsurface geologic and
hydrogeologic conditions contribute greatly to the potential for gas migration. When landfill gas
migration is taking place, on-site and nearby structures are at risk of receiving migrating gas due
to confined spaces in or under the buildings. Landfill gas can enter buildings through cracks in
the foundation or subsurface utility services. Lack of ventilation may result in the buildup of
methane concentrations to explosive limits.
In an effort to eliminate the potential hazards associated with the migration of landfill gas,
NCDEQ has promulgated regulations (15A NCAC 13B .0544 (d)(2)) , which require owners
and/or operators of all C&D landfill facilities to monitor gases at the facility property boundary
and on-site structures. Tables 1 and 2 below provide the present regulatory limits for methane
and hydrogen sulfide at C&D sites.
Table 1 Compliance Levels for Methane
Location Lower Explosive Limit (% LEL) Maximum Methane Concentration in Air
Property Boundary 100% 5% Facility Structures 25% 1.25%

Table 2 Compliance Levels for Hydrogen Sulfide
Location Lower Explosive Limit (% LEL) Maximum Hydrogen Sulfide Concentration in Air
Property Boundary 100% 4% Facility Structures 25% 1.00%

2
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Landfill Gas Monitoring
4.0 Landfill Gas Monitoring
4.1 Proposed Landfill Gas Monitoring Procedure
To provide a means of monitoring methane gas at the landfill, permanent gas migration
monitoring stations have been installed along the perimeter of the Phase II active and closed
landfill areas. These stations are monitored on a quarterly basis.
4.1.1 Permanent Monitoring Station Design and Installation
Permanent monitoring stations have been installed around the active and closed landfill. All the
wells are for detection monitoring. Drawing CD-79B Phase II Landfill Gas Monitoring System,
shows the monitoring wells at the landfill.
4.1.1.1 ACTIVE LANDFILL EXISTING STATIONS
Eight permanent monitoring stations (MGMW-1 through MGM-8) have been installed along the
permit boundary for Phase II (see Drawing CD-79B). The well locations were placed on the east
side of Phase II between the permitted waste boundary and property lines along Rankin Mill
Road. No wells are shown between the active landfill and Buffalo Creek since this is interior to
the property line and Buffalo Creek acts as a cut-off feature.

3
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Landfill Gas Monitoring

Figure 2 Typical Methane Probe Construction
5
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Landfill Gas Monitoring
4.1.2 Gas Migration Monitoring
Reading of the permanent monitoring stations and on site structures will be conducted on a
quarterly schedule. As per existing regulations, the monitoring frequency of individual stations
may be increased if combustible gas is detected above the LEL. Sampling procedure will follow
the manufacturer’s instructions.
All perimeter gas stations shall be monitored for the following parameters.
• Combustible Gas (methane) - with a Landtec GEM 5000 (or equivalent).The station shall
be sufficiently evacuated with the sample pump so that methane concentrations are
constant for at least 30 seconds. The large scale (0-100 percent methane-in-air) shall be
used first. If readings are below 5 percent, the reading will be obtained using the smaller
(0-5 percent methane-in-air) scale.
• Combustible Gas (hydrogen sulfide) - with a Landtec GEM 5000 (or equivalent).The
station shall be sufficiently evacuated with the sample pump so that hydrogen sulfide
concentrations are constant for at least 30 seconds. The large scale (0-100 percent
hydrogen sulfide-in-air) shall be used first. If readings are below 4 percent, the reading
will be obtained using the smaller (0-4 percent hydrogen sulfide-in-air) scale.
Information from the monitoring will be recorded on the field data form (Appendix 1). Any
readings recorded at or above the LEL for methane will be immediately verified and reported as
described in the Contingency Section of this plan.
4.1.3 Continuous Monitoring of On-Site Structures
Select on-site buildings will be equipped with continuous monitoring device to detect
combustible gas concentrations that may accumulate inside the structures.
The device should be rated to detect a wide range of combustible gases and have a methane
detection range of 500 to 10,000 parts per million (ppm) (.05 to 1.0 percent methane-in-air). The
monitor should be installed in an area of the structure where methane gas is most likely to
accumulate. Any verifiable detection of methane in the structures will be addressed and
reported in accordance with the Contingency Section of this LGMP.
4.2 Schedule for Installation of Monitoring Elements
When the City determines that additional permanent monitoring stations are needed, this station
will be installed and documentation will be submitted to the NCDEQ DWM after installation.
4.3 Maintenance and Calibration of Monitoring Elements
The City conducts the following maintenance schedule and calibration procedures for the gas
monitoring elements at the landfill. Training of personnel is conducted when necessary.
4.3.1 Maintenance of Permanent Monitoring Stations
A visual inspection of the permanent stations will be conducted quarterly in conjunction with the
monitoring events. The inspection schedule will increase with any increases in the monitoring
schedule. The condition of following elements will be inspected.
6
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Contingency Plan
• Station label.
• Protective casing and concrete pad.
• Lock.
• Station surroundings including standing water and vegetation.
Any abnormalities regarding the condition of the station will be noted on the field log and
immediately addressed.
4.3.2 Calibration of Portable Monitoring Instruments
4.3.2.1 CONTINUOUS MONITORING DEVICES
Continuous monitoring devices will be maintained and calibrated according to the
manufacturers’ recommendations. Maintenance and calibration will include the following tasks.
• Verification of power to the monitor.
• Ensuring that there is no interference of air flow to the monitor.
• Exposing the sensor to a sample of calibration gas per the manufacturer's recommended
procedure to verify that the monitor is calibrated correctly.
4.3.2.2 PORTABLE MONITORING INSTRUMENTS
Portable monitoring instruments such as the Landtec GEM 2000 will be maintained and
calibrated according to the manufacturer's recommended procedure. For a detailed description
of the maintenance and calibration procedures, the instruction manual should be consulted.
5.0 Contingency Plan
The City will implement the following contingency plan if the landfill gas readings at any
monitoring location exceed the limits set by regulations (see Table 1 – Compliance Levels of
Methane in this plan).
5.1 Contingency Plan Guidelines
If allowable maximum limits for combustible gas are exceeded at the facility property boundary
or in on-site structures, the City will take the following steps.
Step 1: Immediately take all necessary steps to ensure protection of human health and notify
NCDEQ.
Step 2: Within seven days of detection, place the combustible gas levels detected and a
description of the steps taken to protect human health in the operating record.
Step 3: Within 60 days of detection, develop and implement a remediation plan that describes
the nature and extent of the problem and proposed remedy for the combustible gas releases,
place a copy of the plan in the operating record and notify NCDEQ that the plan has been
implemented.
7
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Contingency Plan
Consistent with the above requirements, notifications will be made either in person or by
telephone followed by a facsimile transmission or letter. The City will also contact the following
agencies or personnel as necessary.
Table 3 Contingency Plan Contacts
Agency or Personnel Contact Telephone Number
City of Greensboro Solid Waste Administrator 336-373-2783
City of Greensboro Solid Waste Engineer 336-373-4118 City of Greensboro Landfill Manager 336-373-7658
NCDEQ – Emergency Notification Environmental Specialist 336-771-5000 Fire Department -- 336-373-2356

5.2 Contingency Plan - On-site Structures
The following contingency plan for responding to the detection of excessive combustible gas
quantities detected in all onsite buildings will be implemented by the City.
5.2.1 Immediate Action
• The affected building(s) would be vacated for a period of time determined by the
appropriate emergency officials and all necessary steps will be taken to ensure
protection of human health.
• The landfill operations superintendent, the occupants of the building(s), and the
personnel listed in Table 2 Contingency Plan Contacts will be contacted.
• Notify NCDEQ.
• Following the evacuation, the building(s) will be monitored by City personnel to
determine the extent and source of the methane. Remedial actions such as sealing
cracks or connections would be taken as necessary.
5.2.2 Action within 7 Days
The landfill staff will prepare and place in the operating record a brief report to include, at a
minimum, the following information.
• Results of original and any additional monitoring.
• Summary of actions taken included in Immediate Action section of this LGMP.
5.2.3 Action within 60 Days
5.2.3.1 PREPARE A REMEDIATION PLAN
A remediation plan will be prepared to address at least the following issues.
• Nature and extent of the problem.
• Proposed long term remedial action(s).
5.2.3.2 IMPLEMENTATION OF THE PLAN
NCDEQ will be notified that the Plan has been implemented.
8
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Contingency Plan
5.3 Contingency Plan - Facility Property Boundary
The City's proposed contingency plan for responding to excessive methane gas quantities at the
facility property boundary is provided below.
5.3.1 Immediate Action
• Landfill personnel will be directed away from the affected area and all necessary steps
will be taken to ensure protection of human health.
• The affected area will be monitored daily for a period of time to confirm the methane
concentration.
• If monitoring reports are positive, areas adjacent to the affected zone (including the
property line, utility trenches, and off-site buildings and structures) shall be monitored or
screened by designated personnel.
• If the combustible gas quantities exceed the LEL at the facility boundary, the landfill
manager and the personnel listed in Table 2 Contingency Plan Contacts of this plan,
may be contacted.
• Notify NCDEQ.
5.3.2 Action within 7 Days
The landfill manager will prepare and place in the operating record a brief report to include, at a
minimum, the following information.
• Results of original and any additional monitoring.
• Summary of actions taken included in Immediate Action section of this LGMP.
5.3.3 Action within 60 Days
5.3.3.1 PREPARE A REMEDIATION PLAN
A remediation plan will be prepared to address at least the following issues.
• Nature and extent of the problem.
• Proposed long-term remedial action(s) such as installation of passive or active gas
control system.
A copy of the LGMP will also be placed in the landfill operating record for the facility. NCDEQ
will be notified that the remediation plan has been implemented.
5.3.3.2 BAR-HOLE PROBE INSTALLATION AND MONITORING PROCEDURE
Bar-hole probes may be temporarily installed as a remediation plan and monitored along the
perimeter boundary of the landfill. Bar-hole probes may be used for identifying and tracking
methane migration plumes, as described in the Contingency Plan section, and as a substitute
monitoring method for damaged or malfunctioning permanent probes.
Prior to conducting bar-hole probing, the area will be checked for any subsurface utilities,
conduits, or pipelines. If water or mud covers the desired probe location, then the probe will be
offset to a nearby dry portion of the permit boundary or temporarily eliminated from the
monitoring round. All precautions shall be taken to eliminate the introduction of moisture into the
9
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Safety
monitoring instrument. Any abnormalities in the probe location will be noted on the field data
form (refer to Appendix 1).
The bar-hole procedure will involve pushing a 1/2-to 3/4-inch diameter metal rod a minimum of
2-3 feet into the subsurface soils. Upon removal of the metal rod, a probe connected to Landtec
GEM 5000 or equivalent will be immediately inserted into the hole and sealed to minimize air
infiltration into the sample. A measurement of the sample, along with other pertinent data, will
be taken and recorded on the field data form located in Appendix 1. Readings from the probe
hole will be taken first with the instrument in the “HIGH” or 0-100 percent methane-in-air range.
If a reading above 5 percent cannot be maintained during evacuation for at least 30 seconds,
then the measurement shall be repeated with the instrument in the “LOW” or 0-5 percent
methane-in-air (0-100 percent of the LEL) range. Upon completion of the monitoring, the probe
hole will be backfilled with native soil.
If concentrations of combustible are measured at or above the LEL, additional bar-hole probes
will be installed to assess the lateral extent of the migration. The additional probes will be placed
in a radial pattern starting at the initial probe location and working in 5-foot increments outward.
The pattern will continue until readings of 0 percent combustible are obtained. Information from
this monitoring procedure will be recorded on graph paper to determine the extent of the
migration. The information will be submitted to NCDEQ in the Semiannual Ground-Water
Monitoring Report. If it is determined that off-site migration exists above the LEL, the
information, along with any proposed mitigation measures, will be submitted in accordance with
the Contingency Plan section of this LGMP.
The bar-hole probe equipment will be maintained between monitoring events. Maintenance
associated with the bar-hole probe monitoring includes ensuring plunger bar is clean and free of
damage.
5.3.3.3 IMPLEMENTATION OF THE PLAN
NCDEQ will be notified that the remediation plan has been implemented.
6.0 Safety
Prior to beginning a monitoring procedure, the landfill technician must understand the potential
dangers associated with landfill gas. Not only is landfill gas explosive, it can also present the
following other hazards.
• Landfill gas may cause asphyxiation through oxygen displacement. Proper procedures
must be followed when entering confined spaces which may be potential receptors of
migrating landfill gas.
• Some of the possible trace contaminants associated with landfill gas, such as hydrogen
sulfide (H2S), are extremely toxic. Technicians must be trained in the indicators of H2S
such as its recognizable odor (rotten egg) at low concentrations.
At a minimum, the following items should be addressed by the technician, in addition to any site-
specific safety procedures to reduce the chance of injury.
10
City of Greensboro | White Street C&D Landfill – Landfill Gas Monitoring Plan Safety
• Be aware of the hazards of landfill gas as mentioned above.
• Practice confined space entry procedures when entering structures that have been
evacuated due to the possible presence of landfill gas in confined space.
• Always practice the “buddy” system (i.e., work with a partner who remains outside of the
area of possible exposure) when monitoring for landfill gas.
• Know where all firefighting equipment (i.e., extinguishers, hoses, etc.) is stored and
ensure that it is well maintained.
• Determine whether additional personal safety equipment is necessary.
• Do not smoke or allow others nearby to smoke while monitoring for landfill gas, or at any
time when near landfill waste.
• Know how the monitoring instruments work and how to operate and calibrate them
properly.
• Determine where all nearby subsurface utilities are prior to bar-hole probing.
• Do not use odor as a primary indicator of landfill gas migration.
• Inform the landfill manager or your supervisor of any possible hazards, no matter how
small they may appear.

11
City of Greensboro | White Street Landfill – Landfill Gas Monitoring Plan Attachment 1 – Field Data Form

1
Attachment 1 – Field Data
Form

White Street Landfill Gas Migration Report
Quarter Year

Monitoring Well Methane % H2S Time Date
MGMW-1
MGMW-2
MGMW-3
MGMW-4
MGMW-5
MGMW-6
MGMW-7
MGMW-8

Building Location Methane % H2S Time Date
Phase II Blower
Landfill Maintenance

Shop Area
Restroom
Offices
Landfill Scalehouse
Weighmaster Area
Hallway
Conference Room
Offices
Yardwaste Building

Readings taken by:
Signature:

City of Greensboro | White Street C&D Landfill – Permit Amendment Appendix H – Drawings

H
Appendix H – Drawings

HDR Engineering, Inc. of the Carolinas 440 S Church Street, Suite 1000 Charlotte, NC 28202-2075
704.338.6700
NC License F0116
hdrinc.com
© 2017 HDR, Inc., all rights reserved