3412-OldSalisburyRdCDLF_comment_PermitApp_LOS_FID1359929_20191017

October XX, 2019
Sent Via Email – [e-mail] Ms. Jan McHargue, P.E. Solid Waste Administrator
City/County Utilities
P.O. Box 2511 Winston-Salem, NC 27102 Re: Comments on the Permit Application
Old Salisbury Road Construction and Demolition Debris Landfill (C&DLF)
Forsyth County, North Carolina Permit No. 3412-CDLF-1995, File ID No. (FID) XXX Dear Ms. McHargue:

On October 07, 2019, the Division of Waste Management (DWM), Solid Waste Section (the SWS) received the permit application requesting an approval to continue operating the unlined Old Salisbury Road C&DLF - Phases 1 through Phase VI. The permit application (FID 1359017) was prepared by HDR Engineering, Inc. of the Carolinas (HDR) on behalf of the
Winston-Salem/Forsyth County City/County Utility Commission (the CCU).
The SWS completed a review of the engineering portions of the permit application and has several comments which are stated below. The SWS Hydrogeologist is conducting a review of the environmental media monitoring plans attached to the permit application and will issue the
CCU a separate comment letter to request clarifications, if needed or additional information. The
comments on the engineering portion of the permit application are: Introduction 1. (Section 1.3 & Appendix A)
a. Please provide the required deed document to show City of Winston-Salem as the
landfill property owner, not North Carolina Municipal Leasing Corporation.
Additionally, two lots on the south side of the landfill entrance (by Old Salisbury
Road) are not owned by the City according to the deeds obtained from the web site of
the Forsyth County Registered of Deeds.
b. Please provide a copy of the survey map of the C&DLF property boundary and the
described soil borrow area on the northwest side of the landfill boundary.

Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 2 of 10

2. (Section 1.5) Per Rule 15A NCAC 13B .0543(f)(3), the post-closure land use at this
closed landfill unit is subject to a review and approval by the DWM at that time. Please
add the rule requirements to this subsection.
Engineering Plan 3. Section 2.5 of the Engineering Plan and Section 1.3 of the Closure Plan state that the
C&DLF has the final cover system with side slopes of three (3) to one (1), which was
modified from the 4 to 1 slope originally proposed in the 2002 permit application.
However, the slope stability analyses (both block and global slope failure modes) for a 3
to 1 sloped cover system – under both static and seismic conditions - are not available in
the previous permit applications (from 2002 through 2014).
a. Please provide the slope stability analyses to demonstrate that the proposed 3 to 1
sloped final cover system of the C&DLF can safely stand under both static and
seismic conditions.
b. The selected design parameters for the slope analyses should be used as the
performance standards and minimum criteria stated in the CQA Plan and project
specifications for constructing the landfill final cover system.

4. (Section 2.7) The groundwater underneath the landfill facility is under an assessment
monitoring program; therefore, the section should briefly describe the current
groundwater contamination and likelihood for corrective action.

5. (Section 2.8) The Gas monitoring plan should include hydrogen sulfide monitoring and
the LEL with associated actions that should be taken if exceedance is detected.
6. (Section 2.9) The referenced drawing ES-03 should be included in the permit application.

7. (Section 2.11) The described components of the C&DLF construction activities such as
LCR and geosynthetic liners are irrelevant to landfill at all. A test pad for constructing
the proposed final cover system is required and should be added to the CQA Plan and
project specifications.
8. (Appendix A) Provide a copy of the recorded permit in compliance with Rule 15A
NCAC 13B .0204.

Operations Plan 9. (Section 2.3)
a. Wooden pallets as defined in NCGS 130A-290(44a) are not approved for disposal
except for those pallets generated in C&D activities per NCGS 130A-309.10(f)(12).
Please add the requirement to this section.
b. Please describe the service area of this landfill [Rule 15aNCAC 13B .0537(e)(1)].
Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 3 of 10

10. (Section 2.4)
a. Per NCGS 130A-309.10(f) and Rule 15A NCAC 13B .0542(e), this section shall add
the following wastes to the list of unacceptable / prohibited wastes: recyclable rigid
plastic containers.
b. Please describe if the landfill will accept wastewater treatment sludge and/or asbestos
containing material or wastes for disposal according to Rules 15A NCAC
13B .0542(c) & (d).

11. (Section 2.5) Please describe the operation practices to eliminate, mitigate, or remediate
wind-blown waste per Rule 15A NCAC 13B .0542(g).
12. (Section 2.6)
a. Per Rule 15A NCAC 13B .0542(f), a C&DLF must cover the solid waste with six
inches of earthen material when the waste disposal area exceeds one-half acre and
at least once weekly. Cover must be placed at more frequent intervals if necessary, to
control disease vectors, fires, odors, blowing litter, and scavenging. Please revise this
section in accordance with the requirements of the rule.
b. Please use the correct title of the North Carolina Department of Environmental
Quality (NCDEQ).
c. The referenced document has been amended on July 21, 2017.
13. (Section 2.8) Add the following requirements to this section.
a. The following records must be placed in the facility operating record:
i. Fire/explosion occurrence report.
ii. Approval of an open burning at the site per 15A NCAC 13B .0542(i)(2).
iii. The reports, correspondences, work plans, permit applications and permits
must be placed in the operating records per Rule 15A NCAC 13B .0542(n)(3).
b. All information contained in the operating record must be furnished to the DWM
according to the permit or upon request or be made available for inspection by the
DWM.
14. (Section 4.0) Please add the following requested info to this section:
a. The edge of waste markers must be properly installed and maintained throughout the
life of landfill including the minimum 30-year post closure period.
b. The section states that “each phase should be filled from the high end to allow storm
water to drain freely into the sediment basins.” This statement is misleading because
the leachate generated from wastes in the “high end” of each phase of the C&DLF
drains by gravity, just like the way the storm water drains, freely into the sediment
Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 4 of 10

basins as well. Please clearly describe the leachate and stormwater separation
practices.
c. Please describe the procedures to report an observed leachate breakout and to
investigate the cause, and to conduct the follow-up remedial activities, as needed.
Leachate release sampling and analysis guidance can be found in the following web
link and can be downloaded and appended to the permit application.
https://edocs.deq.nc.gov/WasteManagement/0/edoc/1319075/MSW%20Leachate_Rel
ease_Sampling_Guide.pdf?searchid=22b91c58-be48-4f48-97ec-ae3766e88565
15. Please describe the procedures or practices to control disease vectors per the requirement
in the Rule 15A NCAC 13B .0542(h).
16. Please describe the procedures or practices to ensure that the landfill operations do not
violate any applicable requirements developed under a State Implementation Plan (SIP)
approved or promulgated by the U.S. EPA Administrator pursuant to Section 110 of the
Clean Air Act, as amended [Rule 15A NCAC 13B .0542(i)].
17. (Section 5.2 & Appendix C) Per Rule 15A NCAC 13B .0542(i)(3), landfill equipment /
machinery must be equipped with a fire-fighting equipment to control accidental fires.
Please describe the available fire-fighting equipment for any on-site equipment /
machinery such as fire extinguishers and loads of soil material stockpiled around or
adjacent to the work face.
18. (Section 5.3) Please address the concerns below and add the requested information to the
section:
a. Please describe the procedures to manage a “hot load” in a waste-laden vehicle at
three independent scenarios - approaching the scale house, inside the landfill facility
prior to reaching the working face, at the working face.
b. Open burning of solid waste at the landfill facility is prohibited [Rule 15A NCAC
13B .0542(i)].
19. (Section 5.3 & Appendix C) Per Rule 15A NCAC 13B .0542(i)(4), fires and/or
explosions that occur at the landfill require verbal notice to the DWM within 24 hours
and written notification within 15 days. Written notification must 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.
a. Please add the above-mentioned requirements to this section or Appendix C.
b. The standardized fire report form can be found in the following web link, if the CCU
wants to use the form, please append the form to the Operations Plan.
Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 5 of 10

https://files.nc.gov/ncdeq/Waste%20Management/DWM/SW/Forms/FireOccurrence
Report.pdf.
20. (Section 6.1) In accordance with NCGS 130A-309.25, an individual trained in landfill
operations must be on duty at the site while the facility is open for public use and at all
times during active waste management operations to ensure compliance with operational
requirements. Please add this requirement to this section.
21. (Section 6.2) Per Rule 15A NCAC 13B .0542(j)(1), please describe the established
landfill site security to prevent unauthorized entry.
22. According to the Facility Compliance Inspection Report dated July 26, 2019, an area
inside the landfill facility is utilized for stockpiling concrete, asphalt, and brick (CAB).
Please provide the requested info of this recycling unit in the Operations Plan:
a. The acceptable concrete or brick must be clean, non-painted, and non-contaminated
by a chemical compound as defined in 15A NCAC 13B .0562(1). No concrete in
liquid forms shall be acceptable at this unit.
b. Asphalt as defined in NCGS 130A-294(m) is acceptable at this unit; post-consumer
asphalt shingles are not acceptable at this unit.
c. According to Permit Condition No. 49, Part VII, Attachment 3 of the Permit to
Operate (DIN 23258) dated April 6, 2015, the landfill operation is likely allowed to
remove CAB from the waste stream from the landfill working face. If this waste
recovery operation will continue in the future, please state so in the Operations Plan.
d. Random waste screening should be conducted on each load of CAB upon the receipt
of the waste. Any nonconforming or unpermitted wastes shall be removed, stored,
and properly disposed at the end of that day. However, the nonconforming wastes
such as rebar, metal wire mesh, piping, or wood that can’t be removed from the CAB
without an assistance of a mechanical equipment will be temporarily stockpiled at this
unit and shall be removed and disposed of properly when the CAB is processed.
e. Provide a description of the CAB unit including the extent (in acreage), the maximum
capacity (in cubic yard or tonnage) including both unprocessed waste and proceed
material at any given day. How often will the wastes be processed to become
products? What the end use for the processed material?
f. The CAB unit must be operated according to Rule 15A NCAC 13B .0562, and the
stockpiled CAB must be managed according to NCGS 130A-309.05(c).
g. On the Facility Plan and Operations Plan drawings shows the location and extent of
this CAB unit including stockpiles of unprocessed wastes that are separately
stockpiled from the processed products [15A NCAC 13B .0542(b)(1)(G)].

Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 6 of 10

23. According to the Facility Compliance Inspection Report dated July 26, 2019, a
designated temporary disaster debris storage site (TDDSS), Permit No. DS34-006 is
located inside the landfill facility. Please add the following info of unit in the Operations
Plan:
a. The approved extent (in acreage) of this TDDSS and the location should be added to
the Facility Plan and Operations Plan drawings.
b. The acceptable waste stream at this unit.
c. Describe the approved maximum capacity and dimensions of the debris stockpiles –
height, width/diameters.
d. The TDDSS shall not be used for any waste disposal. The TDDSS can only receive
permitted wastes for storage, process, or treatment after receiving an approval of
activation. Activation of this TDDSS must be requested by the CCU and received
from the Regional Environmental Senior Specialist for the facility; all permitted
debris must be removed from the TDDSS within six (6) months from the activation
date.
Closure & Post-Closure Plans 24. Please use the correct title of North Carolina Department of Environmental Quality
(NCDEQ), not NCDENR, throughout the plans.

25. (Section 1.1) Section 2.5 of the Engineering Plan describes that the final grade contours
for the closed portions of Phases I, II & III areas have been previously capped, certified
and approved. On November 5, 2008 HDR on behalf of the CCU submitted the closure
certification report of the C&DLF – Phases I, II, & III. The referenced closure
certification report and drawings are not available in the DWM records/file system.
a. Please append the certified closure report and drawings to the permit application.
b. Describe the certified closure extent in acreage and the amount of the in-place waste
in cubic yards.

26. (Section 1.3 and Sheet 00C-02) What is the proposed slope for the deck portions of the
final cover system?

27. Drawing Sheet 00C-02 shows the final fill grades of the waste, without the proposed final
cover system, at unclosed portions of the C&DLF as sated in Section 2.5 of the
Engineering Plan. On February 20, 2019, a letter (DIN 7043) from HDR to DWM
requested a modification of the certified final cover thickness over Phases I, II & III by
placing over additional soil excavated from Phase VI construction. The modification was
approved by the SWS on March 18, 2009 (DIN 7042). This permit application is for a
life-of-site permit; therefore, the CCU should submit Closure Plan Drawings including
but not limited to:
Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 7 of 10

a. The layout and cross-sections of final grades/contours of the proposed final cover
over the entire landfill – Phases I through VI. A clear line to delineate two different
final cover systems, constructed according to Rules 15A NCAC 13B .0505(3)(c)
and .0543(c)(1), must be shown on the drawing of this overall cover system. The
details of tie-in of the different two final cover system must be provided in the
Closure Plan drawing(s). It is critical to have this info for landfill cover restoration in
the post-closure period.
b. The details of each proposed components of the landfill cover as described in Section
2.4 of the Engineering Plan and the Closure Plan.
c. The drawings show the layout and details of stormwater management devices and
erosion and sediment control BMPs (as stated in the Erosion Control Plan of the
approved permit to construct application for the C&DLF - Phases IV, V & VI dated
October 2002 and revised through December 2003 & cost items 3 & 9 through 13 of
the closure cost estimate in Appendix E1) including seeding species (Referred to in
Section 2.4 of the Engineering Plan) and schedules per requirements of the Land
Quality Section of the NCDEQ which are incorporated into the final cover system
and existing sediment basins and drainage features (such as the benches or drainage
swales as stated in Sections 2.5 & 3.1 of the Engineering Plan) at the landfill facility.
d. The layout and details of the landfill gas vents or wells to be installed at the final
cover system.

28. (Section 1.6) What are the proposed measures for overcoming the problem of waste
settlement and for facilitating positive drainage of the cover system? For example, slopes
of the landfill final cover system; backfilling and regrading the subsided area, etc.

29. (Sections 1.7 & 1.11) The Closure Plan must be prepared for the site closure for any
possible reason; the statements in the sections that “the gas collection system will be
designed prior to closure” is not acceptable to the SWS. The rule and permit conditions
allow modifications to the Closure Plan later, as needed; therefore, please complete the
gas collection/vent system design in the Closure Plan.
30. (Section 1.10) Please clarify what is the “RMC office.”
31. The SWS does not believe that the CCU will install a landfill gas collection system over
the C&DLF which is financially infeasible; but the landfill is subjected to landfill gas
monitoring. Therefore, throughout the Post-Closure Plan, please revise the “Gas
Collection/Venting System” to Gas Monitoring System and Venting System.

Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 8 of 10

32. (Section 2.4.5) Explosive gas monitoring is conducted at several perimeter landfill gas
wells at the landfill facility as shown on Sheet 00C-01. The routine inspection & repair
should include these gas wells.
33. (Sections 2.4.5 & 2.4.6) The legibility & integrity of ID tag of each well should be
included in the routine inspection & repair task.
34. (Section 2.5.3) Please append a copy of the Post-Closure Inspection Checklist to the Post-
Closure Plan.

35. The edge of waste markers that identify the landfill disposal boundaries should be
routinely inspected and maintained and repaired/reinstalled as needed. Please add edge
of waste markers to the list of inspection activity in Table 2.5-1.
36. (Appendix E-1) Please address the following concerns:
a. (Table 2.7-2) Landfill gas monitoring shall be conducted quarterly per Rule 15A
NCAC 13B .0544(d)(2)(B), not semiannually as shown in the post-closure table.
Please correct the post-closure cost estimate.
b. (Table 2.7-2) The landfill is under an assessment monitoring program right now, are
the costs for lab analytical testing and reporting higher than those for the detection
monitoring program? The unit cost should be revised accordingly.
c. Comparing the 2019 cost estimates from those in previous permit applications (since
2007), all cost items in the cost estimate are the same, except the closure area
increases from 30.3 acres to 31.8 acres after a sloped factor is considered in 2019
application. The SWS calculates the costs for closure and post-closure activities with
the same approaches that had been used by the CCU in the 2014 permit application,
which used the 2007 costs as the basis and increased the amount by the annual
inflation factor. The difference of the cost is about $230,994 dollars as shown below:
CCU – 2019 CCU - 2014 (DIN 21523) with annual inflation adjustment from 2014
through 2019
Closure Costs $5,195,150 $5,301,805
Post-Closure Costs (30-yrs) $2,725,480 $2,849,819
Total $7,920,630 $8,151,624
The SWS concludes the proposed costs for closure and post-closure are too low and are
not acceptable. Please revise the cost estimate accordingly.

CQA Plan
Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 9 of 10

37. The CQA plan is too general and not tailored specifically for this C&DLF at all. This
landfill does not have LCR system, geosynthetic liner system, geocomposite drainage
system, and the CQA Plan shall not contain these items/subjects which are irrelevant to
this landfill construction project. To achieve the purpose of the permit application “to
allow for continued operation of their Old Salisbury Road (OSR) C&D Landfill” as
stated in October 4, 2019 cover letter, please revise the CQA Plan which should specify
the QA/QC requirements of the components of the proposed final cover system stated in
the Engineering Plan and the Closure Plan of the permit application.

38. The CQA Plan should include the technical/project specifications for each component of
the proposed final cover system including, but not limited to
a. Subgrade/intermediate soil cover.
b. Compacted soil liner/ low-permeability barrier. c. Vegetative support layer/ erosion layer & topsoil layer; the considerations for the selected material as stated in Section 2.4 of the Engineering Plan should include soil type, nutrient level, pH, erodibility, etc.
d. Stormwater management and erosion control BMPs- silty fences, slope drains,
diversion berms, drainage channels/benching, erosion control blanket, etc. e. Vegetation/seeding. f. Landfill gas venting system.
39. (Section 2.2.1) Please address the following concerns:
a. The statement in this section is irrelevant to the final cover system. The soil liner
subgrade is the intermediate cover layer and the subbase underneath the subgrade is
C&D wastes. Please revise this section.
b. Please describe the QA testing requirements (including testing items, frequency,
ASTM methods, and passing criteria for each testing item) for the construction of an
intermediate cover layer.

40. (Section 2.2.2) Please address the following concerns:
a. Please describe the QA testing requirements (including testing items, frequency,
methods, and passing criteria for each testing item) of selecting borrow source(s)
which will provide the earthen material for constructing soil liner of the final cover
system.
b. To construct a compacted soil liner, a test pad is required. Please describe the test pad
size, construction procedures including equipment/machinery to be used for
construction, and QA testing requirement for constructing a test pad (including testing
items, frequency, methods, and passing criteria for each testing item).
c. Please describe the construction procedures and QA testing requirements for
constructing the compacted soil liner systems (including testing items, frequency,
methods, and passing criteria for each testing item).
Ms. Jan McHargue, P.E. XXX, 2019 FID XXX Page 10 of 10

41. (Section 9.7) To confirm the rule-required thickness of each layer of the proposed final
cover system of the C&DLF, the following requirements should be added to this section:
a. Establish and layout survey grid points - a 50-feet by 50-feet chessboard pattern over
the closure area is required.
b. At each grid point, the elevation at the following location must be surveyed,
documented, and transferred to the as-built survey drawings.
i. The top of the constructed intermediate cover layer;
ii. The top of the constructed compacted soil liner layer; and
iii. The top of the constructed vegetative support layer/topsoil layer.
c. For a sloped area, the rule-required 1.5 feet thickness of each layer shall be measured
perpendicularly to the slope surface.

42. (Drawing Sheet 00C-02)
a. Please add two more north-south cross-sections over Phases I through III and Phases
IV through VI.
b. What are final elevations of the closed Phase I, II & III? Incorporate all as-built data
from Sheet 00C-01 dated February 20, 2009 (see Note 5) to this drawing.
c. Show the details of “tie-in” of the new and existing final cover systems as stated in
Note 4.
If you have questions about the above-mentioned comments, please contact me at [phone]
or by an email at [e-mail]. Sincerely,
Ming-Tai Chao, P.E.
Environmental Engineer Solid Waste Section, DWM cc: Adam Rickeet, City of Winston-Salem
Michael D. Plummer, P.E., HDR Emily Tucker, EIT, HDR Sherri Stanley, Permitting Branch Head Jaclynne Drummond, DWM Susan Heim, DWM
Deb Aja, DWM