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HomeMy WebLinkAbout6801_OrangeCountyPostClosure_Operations Plan_FID1378553_ 20191204Orange County Landfill – Permit 68-01 Operating Permit Modification - Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 DAA PN: R00592-179N3 ORANGE COUNTY LANDFILL OPERATING PERMIT MODIFICATION SECTION IV OPERATIONS PLAN Orange County Landfill – Permit 68-01 Operating Permit Modification - Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Table of Contents – Page IV-i OPERATIONS PLAN TABLE OF CONTENTS A. INTRODUCTION ...................................................................................................................... 1 1. Purpose ............................................................................................................................ 1 2. Operator Responsibility ................................................................................................... 1 B. OPERATIONS METHODS AND PROCEDURES ................................................................ 2 1. Overview .......................................................................................................................... 2 2. Hours of Operation .......................................................................................................... 2 3. Site Access ....................................................................................................................... 2 4. Waste Acceptance and Special Waste Handling ............................................................. 2 5. Equipment ........................................................................................................................ 4 6. Access Roads ................................................................................................................... 5 7. Vehicle Control and Unloading ....................................................................................... 5 8. Waste Handling Operations ............................................................................................. 5 9. Surface Water Control ..................................................................................................... 9 10. Cleanup Activities ........................................................................................................... 9 11. Vector and Odor Control ............................................................................................... 10 12. Dust Control................................................................................................................... 10 13. Erosion Control .............................................................................................................. 10 14. Tires ............................................................................................................................... 11 15. Record Keeping ............................................................................................................. 11 C. MONITORING AND INSPECTION PROCEDURES ......................................................... 12 1. Groundwater Monitoring Plan ....................................................................................... 12 2. Landfill Gas Perimeter and Interior Monitoring ............................................................ 12 3. Site Evaluations ............................................................................................................. 12 D. CONTINGENCY PLANNING ................................................................................................ 13 1. Wet Weather Operations ............................................................................................... 13 2. Fire Control .................................................................................................................... 13 3. Hazardous Wastes .......................................................................................................... 14 4. First Aid ......................................................................................................................... 14 5. Leachate Disposal .......................................................................................................... 14 E. STAFFING ................................................................................................................................ 15 1. Positions ......................................................................................................................... 15 2. Training.......................................................................................................................... 16 F. SAFETY ..................................................................................................................................... 16 1. General ........................................................................................................................... 16 2. Equipment ...................................................................................................................... 17 3. Personnel........................................................................................................................ 17 Orange County Landfill – Permit 68-01 Operating Permit Modification - Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Table of Contents – Page IV-ii ATTACHMENTS Attachments IV-A through IV-F are not proposed to be modified and are not included in this Application for an Operating Permit Modification. They are listed here for reference only and can be found in the Construction Permit Application (NCDENR Document ID: 6801-MSWLF-1982; Description No: 6821). Attachment IV-A Paint Filter Test (Not Applicable) Attachment IV-B Waste Handling Guidelines (Not Applicable) Attachment IV-C Waste Screening Procedure (Not Applicable) Attachment IV-D Inspection Items Attachment IV-E Sedimentation and Erosion Control Plan Attachment IV-F Operations Manual for Orange County Permanent Household Hazardous Waste Collection Facility (Not Applicable) Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -1 A. INTRODUCTION 1. Purpose The purpose of an operations report is to provide the facility operator with a resource document that has guidance and information to enable the operator to better operate the site. No manual or textbook can be an effective substitute for a qualified and experienced operator. The lessons learned from time spent at the facility do not always easily reduce to words. However, a manual such as this can be a resource for an operator to rely upon for information and guidance. This current revision of the Orange County Landfill Operations Plan reflects the closure of the Municipal Solid Waste (MSW) landfill but addresses the continuation of other solid waste related activities at the facility. The manual is divided into several sections. The subjects covered are: • Operating Methods and Procedures • Monitoring and Inspection Procedures • Contingency Planning • Staffing • Safety A more detailed breakdown of subjects is in the table of contents. 2. Operator Responsibility The facility operator has responsibilities in several areas. The term operator as described here may actually encompass the duties of several people. This section is intended to convey the overall responsibilities of the facility operator function, not a specific job description. One operator responsibility is financial; fee collection, accounting, budgeting, cost effective purchases and use of resources. Another responsibility is personnel management; hiring, training, safety, promotion, scheduling. In addition, the facility operator has responsibilities for operations (equipment, maintenance, security, filling, environmental controls) and planning (new working areas, emergencies, inclement weather, equipment replacement, site improvements). Whether these responsibilities are handled by one person or shared by several people, skillful execution of these duties can make the facility successful. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -2 B. OPERATIONS METHODS AND PROCEDURES 1. Overview This section of the operations manual is intended to give the operator of the solid waste facility some techniques and procedures to help operations run smoothly and achieve the goal of environmentally sound waste disposal. The operator has an important role to play in the development of the facility. The day to day operation will determine the quality of the facility, perhaps more than the initial construction. The operator must understand the purpose of each of the ongoing waste management activities at the closed landfill. Otherwise, seemingly unimportant elements of the facility may be neglected even though they might be crucial to its success. The operator should be familiar with, and refer to, the EPA’s Subtitle D regulations, the rules and regulations of North Carolina’s Department of Environment and Natural Resources, Division of Waste Management (the Division) and the North Carolina Erosion and Sediment Control Planning and Design Manual. In addition, the operator must understand such things as financial controls, public relations, employee relations and planning for emergencies. By mastering the knowledge and skills necessary to become successful, the landfill operator is a professional in the waste disposal industry rather than “the guy who runs the dump”. 2. Hours of Operation The waste management facilities at the Orange County Landfill is open from 7:00 a.m. until 4:00 p.m., Monday through Friday, and from 8:00 a.m. until noon on Saturday (Effective July 2017). The MSW landfill is closed and no longer accepts waste for disposal. 3. Site Access Access to the facility is controlled by a locked gate at the entrance to the site along Eubanks Road. The area is surrounded by heavily wooded areas or natural barriers limiting access. A gate attendant is present during operating hours to screen incoming loads. The attendant screens out unauthorized vehicles and vehicles with unauthorized cargo. Those not permitted into the facility will be turned away at that point. In addition, the vehicles that have waste products accepted by the facility, such as yard waste, tires and white goods, are directed to special unloading areas. Signs are posted at or near the facility entrance that provides information on the hours that the facility is open for public use, the permit number, information regarding materials accepted, directions to separate drop-off areas and to the Construction and Demolition landfill (Permit 68-04), information regarding the waste screening program, and other pertinent information. 4. Waste Acceptance and Special Waste Handling This facility may accept yard waste, tires, electronics, metals, clean wood, pallets, mattresses, and white goods from residents and businesses of Orange County and its municipalities, for collection Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -3 and recycling or disposal off-site. There are also designated C&D and wood grinding areas on-sites to be activated for processing disaster debris for disposal off-site. A permanent HHW Collection Facility is located adjacent to the Inactive/closed South Landfill Unit. This HHW facility ceased accepting material in August 2018. The facility was inspected on November 11, 2018 by John Patrone of the North Carolina Department of Natural Resources. At the time of the November inspection Orange County had not determined what the empty building would be used for but made clear that the facility would be used for future waste management operations as needed. 1. The County proposes to use this facility as a holding facility for some non-regulated, non-hazardous materials. As well, the County proposes to use this facility for paint mixing and to potentially conduct a paint exchange program for Orange County residents. 2. The County operates two active, permitted, and permanent HHW collection centers. One is located on Walnut Grove Church Road in Cedar Grove, NC and holds Permit No. 68-05. The second facility is located on Eubanks Road in Chapel Hill, NC and holds Permit No. 68-06. The County will use this facility to store paint received from those two HHW facilities. For the latex paint received, and desired to be dried, it will be processed by mixing it with acceptable solids to dry the paint for transport and disposal to the landfill. For paint not suitable for mixing with solids and landfill disposal, or should the County desire to not dry the paint, it will be processed for transport and then transported by a licensed hauler to a licensed Treatment, Storage and Disposal Facility. Should the paint be dried, paint will be mixed within the paint cans containing the paint, metal vats, plastic lined containers, such as a plastic lined carboard box, or similar containers conducive to drying paints. Mixing will be done by adding an appropriate amount of kitty litter, clean soil, sawdust, shredded paper or similar material to adequately dry the paint. The dried consistency of the paint will be determined by Orange County Solid Waste employees to verify the paint has thickened adequately and no liquid remains. Drying will be performed by manual labor. Staff performing drying procedures will wear appropriate safety personal protective equipment (PPE). Dried paint will be disposed of as MSW in an approved, permitted facility. Dried paint will be transported to the City of Durham Transfer Station for transfer to Sampson County Landfill. As the dried paints will be disposed offsite, the County will be responsible for ensuring solidified paints cross the scales and appropriate tax is paid. Taxes will be paid in cost savings by not paying a HHW vendor to dispose of the paint. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -4 The County proposes to designate this facility as storage area for paints and household hazardous wastes for short periods of time. HHW material will be stored in this facility in the event that the County’s two HHW Collection Facilities are unable to store materials. An example of this might be during the Spring/Winter Holiday periods when residents in the County are cleaning their homes i.e. “Spring Cleaning.” HHW will also be stored in this facility during any event that causes delays in regular transport. For example, following a severe weather event which may impede safe travel for transport and disposal. This facility will not be used as a permanent collection facility. The County will remove any excess/emergency amounts of HHW as soon as reasonably possible not to exceed 30 days. Materials accepted at the facility will be directed to special handling areas. An overall site plan is included at the end of the Operation Plan. 5. Equipment The facility, including the separately permitted C&D landfill and solid waste and recycling operations located on the north side of Eubanks Road, currently uses the following equipment. C&D Landfill:  one dozer  one compactor Mulch Management:  one bucket loader MSW Landfill: (CLOSED) Metal and White Goods Handling:  hoe  two 90-cubic yard trailers  tractor Wood Grinding Operation:  horizontal grinder  track loader  hoe  conveyor  trommel screen  walking floor trailer Miscellaneous:  dozer  motor grader  water truck  off-road truck  repair truck  sweeper Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -5 This equipment is adequate for operations. Equipment from one area can supplement equipment in other waste management areas and equipment is subject to change based upon operational need. In the event of an extended breakdown of equipment, the County has funds set aside for temporary rental of replacement equipment. This list of equipment may vary depending upon replacements and additional purchases. 6. Access Roads The County maintains a system of all-weather access roads at the facility to allow customers to access the various collection locations and to allow the County to process and remove collected materials and maintain the closed MSW landfill 7. Vehicle Control and Unloading Customers entering the facility will be controlled by the operations staff using the following procedures: a. Eliminate traffic that does not need to go to the facility. A separate household convenience center is provided on the north side of Eubanks Road, east of the landfill facility, for use by County residents. b. Screen and weigh incoming traffic at the Attendants Station. Incoming vehicles will stop at the Attendant's Building. The Attendant can screen out unauthorized vehicles and vehicles with unauthorized cargo. Those not permitted into the facility will be turned away at that point. Vehicles admitted to the facility will be directed to the appropriate unloading areas based on material being delivered. c. An adequate number of directional signs are posted to control the flow of traffic. Signs are large enough and brightly marked to attract the drivers’ attention. Signs will be kept clean so they can be read. Commercially manufactured reflectorized signs are recommended because they are quite durable and will last many years. Spares should be maintained to replace signs that may be damaged. 8. Waste Handling Operations The facility maintains the following services: • a landfill gas collection system, • collection and processing of vegetative waste, • tire collection for recycling, • collection of metal for recycling, • white goods collection with removal of residual freon gas prior to recycling, • electronics collection for recycling Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -6 • recycling processing for sorting, preparing and baling plastics bottles, metal cans and glass bottles for market, • hazardous household waste temporary storage(discussed above in Section 4), All materials are removed from the facility by the County or vendors. No materials are permanently disposed at the facility. Landfill Gas Collection System – The University of North Carolina at Chapel Hill (UNCC) owns and operates the gas collection and conveyance system at the closed landfill units. UNCC performs the weekly and monthly gas monitoring and system maintenance and adjustments. The collected gas is either flared on-site or transmitted off-site to gas powered electric generator that produces electricity that is sold to the poser supply company. Per the lease agreement between the County and UNCC, UNCC is responsible for all of the maintenance, operation and permitting requirements for the system. Access to the system and its components is controlled by fencing to prevent unauthorized personnel from adjusting the system. UNCC has a remote site that monitors the performance of the system and alerts the County of any issues that arise. Clean Wood and Vegetative Waste Processing- The County collects clean wood and vegetative waste at the facility and them grinds the two products making boiler fuel and mulch, respectively. Both materials are handled in a similar manner. The following process shall apply to both unless noted otherwise. The materials are co-located in an area approximately 3.1 acres in size. Materials are dropped off by customers on the southern half of the area where they are stored until a sufficient amount of material has accumulated for efficient grinding operations. Materials are placed into windrows with maximum dimensions of 50 feet wide, 12 feet high and 260 feet long. A 25-foot wide access way is maintained between windrows to facilitate fire control. The maximum amount of material that the site can store is approximately 18,000 cubic yards. Producing a highly quality mulch that citizens want requires proper treatment to ensure that the outgoing product will not create an excessive number of weeds. Many people apply mulch to prevent weeds in flower gardens, so introducing weed seeds is counter-productive. The process for treating mulch is very similar to making compost, where controlling temperature and moisture is essential. The County, however, does not produce compost. Due to the nature of the earth products, though, it is possible for finer textured material to form during the entire process that will give the appearance of compost, but the material has been managed so that it has not been through the time/temperature cycle needed for composting. Grinding of material happens on the western side of the processing area and finished product is sold from the eastern side. Ground material is managed so that the internal temperature of the pile Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -7 does not exceed 132 degrees Fahrenheit. The processed material windrows are turned once temperatures reach that temperature, but no longer than typically 30 days. The turning process moves material from west to east in the processing area so that the oldest material is sold first. The temperature range is watched carefully to balance the ability to kill weed seed and not have the pile spontaneously combust. In the event of a fire, the onsite equipment can be used to isolate the fire and either snuff it out or spread it out on the paved area. The County also maintains a water truck on site that is kept loaded with water that can be used to extinguish a fire, or to wet down hot spots that have been put out by other mechanical means. The site is served by the New Hope Volunteer fire department. In the event of a fire, the operator should notify his supervisor immediately. The supervisor will be responsible for documenting the event, researching the cause, and reporting the incident to DEQ. When temperatures are being checked, the operator should also check the moisture of the mulch using the “hand/roll” technique. This process requires the operator to grab a handful of material from the inside of the mulch pile and compress it into a ball. If water squeezes out, the pile is too wet, if it falls apart immediately, it is dry, and if there is a slightly moist feel to it or if it maintains a slight clump, the moisture level is appropriate. Clean wood waste is monitored in much of the same manner, except that it rarely lasts long enough to be turned. The processed clean wood, or boiler fuel, is typically produced in the southwest corner of the processing area and loaded into customers trailers using either a conveyor located adjacent to the pile, or with a loader. Mulch is loaded into customers vehicles or trailers using a 3- cubic yard loader. Scrap Tires – Scrap tires are collected and temporarily stored just west of the entrance to the facility on the north side of Eubanks Road. In the past, two different methods for handling the tires have been used by the outside vendors that the County contracts with to dispose of the tires. Under the current methodology, the vendor keeps a backhoe with a grappling attachment on site and brings in trailers when tires need to be loaded and hauled off site. The backhoe is located directly adjacent to the loading platform where the trailer is backed up against. Customers drop off their tires next to the backhoe, and as the pile grows, tires are dropped off further away from the loading platform. County staff use loaders that are onsite for other various functions to push the tires forward to the loading platform. The backhoe loads the tires closest to it and works its way outward from the loading platform. This process ensures that the oldest tires onsite are loaded first. Tires are loaded onto trailers and removed from the site three to four times a week. The other method that has been used and may be available to the County at some point in the future is having trailers onsite that are loaded by the vendor three times a week. Under this scenario, three trailers were typically kept on site, and swapped out after they had been loaded. The tires are managed in the same manner as discussed above, expect a laborer is used to hand load the tires into Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -8 the covered trailers. The laborer will work from the tires closest to the loading platform and work his out. A County operator will push the pile forward towards the loading platform as needed. Per 15A NCAC 13B.1107, the maximum size of the pile shall not exceed 200 feet in length, 50 feet in width and 15 feet in height and the maximum number of tires permissible on site is 60,000. The County stores the tires on a concrete pad that is approximately 50’ by 50’ which is well below the maximum pile size prescribed by the regulations. Because most tires are removed from the site after only a few days, issues with mosquitos and rodents have not been experienced. However, County staff does monitor the tire pile to ensure that vectors do not become a problem. In the event that vectors are present, the County has contracts with outside pest control vendors that are used to limit their activity. All loads containing tires are weighed in at the scale house and the loaded trailers that are being removed by the tire vendor are weighed out. The tickets are kept for record keeping purposes. White Goods and Scrap Metal – The County receives white goods and metal at the solid waste facility in two different piles on a concrete pad that is approximately 80’ deep and 130’ long. The pad was constructed with a push wall and grade separation so that trailers can be loaded from the high side using a backhoe that is dedicated to the metal area. The County currently employs multiple staff members that are licensed to remove refrigerant from appliances containing such. The extraction system used by the County is connected to a ten-pound tank that collects the freon. Quantities recovered from the disposed appliances is typically small and takes several months to fill a tank. Once the tank has reached or is near capacity, the County contacts their household hazardous waste vendor to collect the container. The tank and extraction equipment are kept in a locked metal building located adjacent to the metal collection pad. The licensed removal personnel keep a log of the appliances and the amount of refrigerant that was collected. Once the refrigerant has been removed, the appliances are then placed in the trailer to be hauled to a scrap metal yard. Scrap metal is also collected and loaded into a trailer at this location to be shipped to a scrap metal yard for processing. The metal is typically dropped off by customers or comes from the C&D landfill where operators will remove the metal base frame of mobile homes that have been brought in for disposal. An operator is stationed near the metal pad and inspects each load that is dropped off. Electronics – A metal building located on the south side of Eubanks Road, east of the closed South MSW unit is used for collecting and processing electronic equipment for recycling. Materials are brought to the building from their collection point and sorted by like components. The material is then palletized, shrink wrapped and loaded onto a trailer located near the building. Once the trailer is full, typically weekly if not sooner, it is hauled off site by the current electronic recycling vendor employed by the County. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -9 Recycling Pad- The County operates a recycling processing pad in accordance with NCGS 130A- 309.05 (c) where recyclable materials are brought to be inspected and processed for market. The majority of incoming recyclables come from single stream collection efforts throughout the County. These materials are dumped onto the pad where a loader operator pushes up the material for loading into ta trailer that will transport the material to a Materials Recovery Facility for processing. While the operator if pushing the material, he is also observing the material for contamination that needs to be removed from the recycling stream. Contaminants that are removed are placed in a small front load dumpster that is placed near the pad. The dumpster is emptied daily or every other day by County staff and taken to the transfer station for disposal. The County also operates a baler that is used to palletize large rigid plastics for transport and sale to secondary markets. The materials are dumped onto the recycling pad floor and loaded with a small skid steer into the hopper for the baler. During the loading process, the operator is observing the material for contaminants that need to be removed and disposed of properly. Baled plastics are then loaded into an enclosed trailer, and once full, the trailer is taken to the receiving processing facility. 9. Surface Water Control The closed MSW landfill at the facility uses a system of diversion berms, swales, and piped slope drains to perimeter drainage channels to avoid erosion of the final cover. The perimeter drainage channels discharge to a sediment basin before collected runoff is discharged off-site. These controls were designed for the 25-year, 24-hour design storm and are periodically inspected and repaired as necessary. Additional controls are constructed to divert stormwater away from the remaining material collection and processing facilities located on-site in order to provide customers with all-weather access. The diverted stormwater from these locations is also directed to sediment basins prior to off-site discharge. Stormwater discharged from the site is subject to NPDES permitting requirements. 10. Cleanup Activities During the day to day operation of the facility, debris will be spilled on the roads, litter will blow from the collection areas, mud will accumulate in the ditches, and the dirt will be tracked on the roads. These are unavoidable circumstances and are common to all waste management facilities. One of the characteristics of a well-run facility is that litter, debris and mud are cleaned up on a regular basis. The most successful techniques are a combination of a continuing program and periodic major clean up campaigns. One of the "extra duties" that all employees should share is site clean up. Operators can pick up blowing litter during periods when they are not performing their primary task. The entrance will be Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -10 cleaned up daily. Other employees can assist with that job particularly during periods of windy weather in the spring. Windblown material will be collected at the conclusion of each operating day. 11. Vector and Odor Control The closure of the MSW landfill and the operation of the landfill gas collection system should eliminate the primary potential source of vectors and odors at the facility. If abnormal quantities of vectors or odors are detected, then the landfill final cover and gas collection system will be inspected, and any repairs or operational changes will be made to control nuisances. The remaining material collection and processing activities at the facility are generally not associated with the attraction of vectors or generation of odors. If local problems are detected, the sources of odors or vector attraction will be identified and removed or contained. If necessary, authorized methods of vector control/removal will be used. 12. Dust Control Excessive dust can be a nuisance and a hazard. Dust can irritate eyes and lungs. Water can be used but only to the extent that no saturation or ponding occurs. Maintaining areas for use in wet weather and removing mud deposited on roads will also minimize dust generated. 13. Erosion Control Erosion control at the facility will comply with the permit drawings and the approved sedimentation and erosion control plan. A copy of the sedimentation and erosion control plan is attached as Attachment IV-E of the Construction Permit Application (NCDENR Document ID: 6801-MSWLF- 1982; Description No: 6821). No major earth moving activities are anticipated for the facility since the MSW landfill has been closed. Erosion control will consist of maintaining the various components of the site drainage system, including sediment basins. Vegetation will be maintained on the closed landfill and other areas of the site not used for material collection and processing. Erosion control maintenance will consist of three activities. Each will be addressed separately but should be considered an integral part of the erosion control process. a. Maintenance of existing slopes and ditches involves inspecting and repairing areas where water has been directed and are subject to erosion. Repair may consist of refilling washouts or ditches, lining with stone or riprap, or cutting new ditches when the old ones are full. b. Temporary sediment barriers will be used at the base of slopes when any repair operation begins and continued until vegetative cover is established. Silt fences, and/or brush barriers can be used. Either type will have to be replaced periodically. Brush barriers typically maintain their effectiveness throughout the construction period. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -11 Silt fences should be constructed using a non-woven geotextile fabric that is resistant to ultraviolet light and is specifically manufactured to be used in siltation control fences. Brush barriers will be brush, stone, root mat, and other spoil material. The barrier will be mounded in a row with a minimum of five feet in width and three feet in height. Temporary sediment barriers will be inspected after each significant rainfall. c. The vegetative cover, sufficient to restrain erosion, should be maintained. Any repair area to be seeded should be tested for nutrients and pH, and fertilized as needed. These must be worked into the top one inch of the surface. Apply seed at the following rate: 100 lb/acre ............... Kentucky 31 Tall Fescue 30 lb/acre ................. Sericea Lespedeza 10 lb/acre ................. Kobe Lespedeza 25 lb/acre ................. Pensacola Bahiagrass Hydroseeding may be used in lieu of hand seeding or mechanical seeding. Seeded areas must be mulched to protect the seed until a stand of grass is established. The County reserves the right to revise the seeding mixture based on seasonal variations. 14. Tires Whole tires are collected at the facility from customers and are currently being removed from the site by a private contractor. 15. Record Keeping The facility maintains records of its activities. At a minimum, the following records will be maintained at the facility following closure of the MSW landfill [from list provided by NCDEQ, Waste Division]: Operating Record Includes e. Amounts by weight of solid waste received at the facility to include source of generation. f. Landfill Gas monitoring results and remediation plans required. g. Demonstration, certification, finding, monitoring, testing, or analytical data required by Rules .1630 through .1637. h. Monitoring, testing or analytical data as required by Rule .1627. i. Cost estimates and financial assurance documentation required by Rule .1628. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -12 Operating Record Includes Other Required Recordkeeping a. Contingency Plan. c. Scrap Tire Certification Forms (scrap tire collection, processing and disposal sites). d. Operation Plan. [.1626(10)(c)] e. Leachate Management Plan .1626(12) (sites with leachate collection system only). h. Records of monitoring information required by the Permit .1604(2)(K)(ii). C. MONITORING AND INSPECTION PROCEDURES 1. Groundwater Monitoring Plan A groundwater quality monitoring plan has been prepared separately. The ground and surface water quality will be monitored in accordance with the approved version of that plan. 2. Landfill Gas Perimeter and Interior Monitoring A landfill facility gas monitoring plan has been prepared separately. Landfill gas will be monitored in accordance with the approved version of that plan. 3. Site Evaluations The facility operator must inspect and maintain the closed MSW landfill. A suggested post-closure inspection schedule is provided in the Post-Closure Plan. Inspections are suggested after every major storm event to confirm that excessive erosion or other damage has not occurred; monthly inspections of security control devices and for leachate seeps and repairs made as necessary; and complete inspections of the site made quarterly and repairs made as necessary. Attachment IV-D of the Construction Permit Application (NCDENR Document ID: 6801-MSWLF-1982; Description No: 6821) includes a detailed list of the items that need to be inspected. The list indicates the frequency of the inspections. The list has blank lines to allow the operator to add items as experience dictates. Items on the list pertaining to an active landfill are not applicable to a closed facility. Monthly informal inspections of the active material collection and processing facilities at the site is also recommended to identify housekeeping needs, adequacy of facilities, customer convenience, and efficiency of operations. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -13 D. CONTINGENCY PLANNING 1. Wet Weather Operations The County maintains a system of all-weather roads at the facility to allow customers access to all material collection and processing locations at the site during inclement weather conditions. An all- weather access road to the top of the landfill is also maintained for maintenance. 2. Fire Control In accordance with Rule .1626(5)(b) of the Solid Waste Management Regulations, "open burning of solid waste, except for the infrequent burning of land clearing debris generated on site or debris from emergency clean-up operations, is prohibited at all MSWLF units. Such infrequent burning must be approved by the Division." The closure of the MSW landfill with the installation of an active LFG collection system reduces the chance of fires developing within the waste by removing the source of oxygen and providing for the extraction of methane gas. The final cover and LFG system will be periodically inspected to ensure they are functioning as intended. The potential for the development of fires at the facility at the closed landfill or at other locations; however, remains. To provide immediate capability to stop small fires, each piece of equipment is fitted with at least one multi purpose dry chemical fire extinguishers. The fire department can provide training in proper use of fire extinguishers. This training is highly recommended since proper fire extinguisher technique is not obvious and must be learned. For larger fires the Fire Department should be called. All facility employees should be instructed in the fire fighting techniques. Emergency numbers are listed in the Contingency Plan section of Attachment IV-C in the Construction Permit Application (NCDENR Document ID: 6801-MSWLF-1982; Description No: 6821). This list should be posted in a conspicuous place and updated as needed. The facility operator should review the fire fighting procedures with the fire department to gain their cooperation and to avoid confusion when they arrive at the facility. Authorized representatives of the Fire Department should be provided keys to the entrance gate. They should also be given permission to cut the lock if necessary to gain entry. If fires do occur on the landfill, the Division of Waste Management will be verbally notified within 24 hours of the fire and written notification will be submitted to the Division within 15 days of the occurrence. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -14 3. Hazardous Wastes The closure of the MSW landfill essentially eliminates the potential for hazardous waste to be disposed at the facility. Screening by the scale staff and attendants will verify that unauthorized wastes are not left at the facility. A Household Hazardous Waste Facility has been constructed on- site. It’s operation is addressed under a separate permit. 4. First Aid The use of the facility by customers who may be unfamiliar with the site and the handling of potentially heavy or otherwise dangerous materials could result in accidents leading to injuries. Immediate response is critical to the successful treatment of an injury. At least one person trained in basic first aid should be on the site at all times. It is preferable that at least one person trained in advanced first aid be on the site. These courses are available at a modest cost from the American Red Cross and many rescue squads. An industrial first aid kit should be kept at the office at all times where everyone can find it. Vehicles should have smaller portable first aid kits. The telephone number of the nearest rescue squad should be posted beside every telephone. In addition to first aid, at least one person on duty should have training in Cardiopulmonary Resuscitation (CPR). This training is available from the American Red Cross or the American Heart Association, again at a modest cost. Those who have received training should have it noted in their personnel records. All injuries should be reported and the appropriate reports filed. This will protect the County and the employee in the case of a workman’s compensation claim. It will also give the supervisor a record to check. If the same type of injury keeps reoccurring, then the cause or a method to avoid the injury causing action should be found and changes in procedures made. 5. Leachate Disposal Leachate generated and collected within the closed landfill is discharged directly into the local sewer system via gravity. In the event the local sewer system is shut down for any reason, leachate will be stored in the landfill for no more than 10 working days. If after 10 working days, the local sewer system is still not functional, leachate will be pumped from the landfill through cleanouts at the sump(s) or on-site manholes into a tanker truck for disposal at the local publicly owned treatment works. As soon as the local sewer system is functional, leachate will resume being directly discharge to the sewer system. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -15 E. STAFFING 1. Positions The Solid Waste Management Director has overall responsibility for site operations, as well as general site planning. The Director is responsible for policy and field design decisions. The County Solid Waste Management Department is the primary site operator. The County is responsible for the daily activities at the facility. The Director, or his duly appointed representative, will directly supervise and inspect daily operations. The on-site supervisor will administer the daily instructions and be responsible for the proper operation and maintenance of the facilities and equipment. Additional duties may include personnel administration and handling problems with customers. He should also keep the Director up to date on the needs and problems of the facility. The Director and on-site supervisor(s) are the primary contacts for coordination with the University of North Carolina Chapel Hill (University) and its contractors for the operation and maintenance of the Gas Collection and Control system (the “GCCS system”). The Landfill Gas Agreement (the “Gas Agreement”) between the County and the University defines the roles and responsibilities of the parties for all work related to landfill gas management on the landfill. Although the County will retain the ultimate responsibility for compliance, they will rely on the Gas Agreement to fulfill much of their responsibilities for development and daily operations of the GCCS system. Details are provided in the Landfill Gas Management Plan of the Permit Modification dated July 2009 (NCDENR Document ID: 6801-MSWLF-1982; Description No: 8586). The landfill gas engineer for the University has recommended that the GCCS operations staff be trained in the operations and management of landfill gas systems and consult references such as the “Landfill Gas Operation & Maintenance Manual of Practice” prepared by the Solid Waste Association of North America (SWANA) or similar. The County intends to require the University to comply with that recommendation. Facility attendants are responsible for daily facility servicing and minor maintenance, packaging and removal of collected materials, and other miscellaneous duties such as site clean up. The gate attendants are responsible for handling the incoming vehicles. Vehicles must be processed through the attendant’s station and accurately charged for their waste. Vehicles must be screened and sent to the proper part of the facility for the materials they are carrying. The gate attendants should be familiar with the operational aspects of the facility. They can then give customers accurate answers to their questions about facility rules and policies. Gate attendants assist with other general activities. Occasionally, it may be necessary to add additional staff for special projects such as major cleanup campaigns and construction. Other County staff or part time employees should be considered. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -16 2. Training It is unreasonable to expect any employee to maintain a high degree of skill without periodic training to learn new skills or refresh old skills. Training is available for employees from many sources. Solid waste trade and professional associations sponsor seminars and training at low or no costs. The American Red Cross, Fire Department and National Safety Council can provide first aid, fire and vehicle safety information. Equipment manufacturers are a source of information on equipment operation. The following training program can be implemented at a fairly low cost: Subject Employees Frequency Waste Handling Supervisor, Operators Initial Employment & Annual Equipment O & M Operators Semi-Annual and with all New Equipment First Aid, CPR Safety Coordinator Annual Fire Control All, Fire Department Annual Hazardous Material All Annual Recognizing Hazardous Wastes All Annual General Safety All Operators Monthly, Weekly F. SAFETY 1. General The cost of an accident can be several times the medical expenses required to bring an employee back to work. The personnel working at the facility are exposed to a variety of hazards from heavy equipment, vehicles and the many materials they handle. The sources of injury could be fire or explosion, contact with contaminants, falls, equipment accidents, traffic accidents and enclosed areas such as manholes. An effective safety program will train the employees to see the hazards early and avoid them or change the situation to eliminate the hazard. The principle of risk management should be incorporated into daily operations. First, inventory activities to assess hazards. Once the hazards are recognized, determine who is exposed to the hazard and how often the exposure exists. The goal then is to do one of three things. a. Reduce the exposure to the hazard by isolating the hazardous situation or eliminating it. An example may be to place a guard rail next to a steep slope. b. Change the frequency of exposure to the hazard. For example, the servicing of a piece of equipment may be put on a less frequent cycle by use of a higher grade oil or part. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Page IV -17 c. Where exposure cannot be guarded or reduced the employee must be trained to work in the hazardous environment and give the necessary protective equipment. An example will be the inspection of the leachate collection system. 2. Equipment Most safety training can be accomplished by use of the many packaged training programs. Some equipment manufactures can provide training films that are usually available on a loan basis. The following checklist for safe equipment operation may be useful. a. Check equipment before starting b. Use steps and handholds c. Keep steps clean d. Inspect area before moving e. Operate from driver’s seat f. Wear seat belts g. Never mount moving equipment h. Authorized passengers only i. Keep bucket or blade low j. Check blind areas k. Keep enough clearance l. Avoid sidehill travel m. Avoid excessive speed p. Check work area q. Park on level ground r. Lower attachments to ground when parked s. Never jump from equipment t. Avoid leaving equipment unattended u. Always have adequate lighting v. Clean equipment before repairing w. Remain in seat during equipment adjustments 3. Personnel Steel toe safety shoes with steel sole plates and gloves should be required apparel for facility personnel. If necessary, dust protection should be provided. Good hygiene should be stressed to all personnel to prohibit the spread of contamination. Smoking on the landfill and in any confined area should be discouraged. Orange County Landfill – Permit 68-01 Operating Permit Modification – Operations Plan July 28, 2009 Revised January 2012; April 2013; September 2017; May 2019; December 2019 Figure FIGURE 1 OVERALL SITE PLAN 515 515 510 510 505 505 500 500 495 495 490 490 485 485 480 480 475 475505 520 519 518 517 516 516517518 519520 PHASE I ACTIVE CLOSED ORANGE COUNTY SOUTH MSW LANDFILL (PERMIT 68-01) EUBANKS ROAD C & D LANDFILLPHASE I ACTIVE CLOSED ORANGE COUNTY LANDFILL UNIT CLOSED ORANGE COUNTY LANDFILL UNIT 1 inch = ft. ( IN FEET ) 0200 200 400 200 100 GRAPHIC SCALE P:\R00\500\R00592\R00592-179N\CAD\R00592-179N\R00592-179N_EXISTING.dwg December 3, 2019 2:46:15 PMDESIGNED BY: DRAWN BY: CHECKED BY: SCALE: DATE: PROJECT NUMBER: REVISIONS R00592-179N OCTOBER 2019ORANGE COUNTY EUBANKS ROAD C&D LANDFILLPERMIT 68-04 RENEWALORANGE COUNTY, NORTH CAROLINAEngineering Surveying Environmental Services114 Edinburgh South Drive, Suite 200Cary, NC 27511919-873-1060 Fax: 919-873-1074www.daa.comNC Firm License # C-0861Virginia Beach, VAHampton Roads, VAFayetteville, NCCharlottesville, VABlacksburg, VARichmond, VANorthern Virginia1" = 150' CTC JR. JAJ CTC JR. 1OVERALL SITE PLAN480 LEGEND December 4, 2019 Mr. Ming-tai Chao Permitting Branch, Solid Waste Section Division of Waste Management, NCDEQ 217 West Jones Street Raleigh, NC 27603 RE: Response to 5/31/2019 Review Comments Orange County Solid Waste Management Facility Revised Operations Plan Draper Aden Associates Project No. R00592-179N Dear Mr. Chao: On behalf of Orange County, Draper Aden Associates offers the following responses to comments from the above-mentioned review comments. Our responses to the May 31st, 2019 comments are denoted below in bold: 1. (Section B.4 – Waste Acceptance and Special Waste Handling, Page IV-3) Please address the following concerns of the paint disposal. The plan proposes to add a solid waste to solidify the collect latex paints. Please provide, in a minimum, a) the description of the on-site location to conduct the proposed activity and add the location to the operation plan drawing Response: Paint mixing and storage will be performed at the Old, inactive HHW building under Permit 68-01-HHW. Language has been added to the Narrative under Section B-4. The location of this building has been denoted on the Overall Site Plan in Figure 1. b) what kind solid waste will be used to solidify the paints, the detailed procedures to mix and solidify the paints with solid wastes, the descriptions of vessel/container to be used for mixture/solidification, mixing mechanism, any safety measures and spill preventions how to determine the paint is dry enough Response: The following paragraph has been added to the Operations Plan under Section B-4: “Should the paint be dried, paint will be mixed within the paint cans containing the paint, metal vats, plastic lined containers, such as a plastic lined carboard box, or similar containers conducive to drying paints. Mixing will be done by adding an appropriate amount of kitty litter, clean soil, sawdust, Mr. Chao December 4th, 2019 Page 2 of 3 P:\R00\500\R00592\R00592-179N3\CORRESP\LTR 19 1204 Chao - Response to Comments Operations Manual - LAB.docx shredded paper or similar material to adequately dry the paint. The dried consistency of the paint will be determined by Orange County Solid Waste employees to verify the paint has thickened adequately and no liquid remains. Drying will be performed by manual labor. Staff performing drying procedures will wear appropriate safety personal protective equipment (PPE).” c) descriptions of dry/solidify paint removal and ship to an off-site disposal facility. Response: The following paragraph has been added to the Operations Plan under Section B-4: “Dried paint will be disposed of as MSW in an approved, permitted facility. Dried paint will be transported to the City of Durham Transfer Station for transfer to Sampson County Landfill.” Identify which permitted landfill will and can accept the dry or solidified latex paint (treated paint). The Orange County C&DLF, Permit No. 6804-CDLF-2005 may not accept the treated paint for disposal. This is because the paints from HHW facilities may not be considered as a C&D waste stream except the County can approve the paint and solid wastes to be used for solidification are meet the Rule 15A NCAC 13B .0532(8). Response: See response above. Regarding the off-site disposal of the collected paints mixed with solid wastes, the SWS advises Orange County that if they accepted the material as HHW for recycling and there was no disposal tax paid by the citizen, the county would be responsible for ensuring paints mixed with solid wastes crosses the landfill scale and a tax is appropriately paid. Response: The following paragraph has been added to the Operations Plan under Section B-4: “As the dried paints will be disposed offsite, the County will be responsible for ensuring solidified paints cross the scales and appropriate tax is paid. Taxes will be paid in cost savings by not paying a HHW vendor to dispose of the paint.” 2. (Section B.8 – Waste Handling Operations, Page IV-5) The facility does not operate a compost unit. The bullet item 3 and Figure 2 – Overall Site Plan indicate a compost unit is operational. Please remove compost from the operation plan. Response: The compost unit has been removed from the bullet list under Section B.8. As well, the compost unit has been removed from the Overall Site Plan within Figure 1. Mr. Chao December 4th, 2019 Page 3 of 3 P:\R00\500\R00592\R00592-179N3\CORRESP\LTR 19 1204 Chao - Response to Comments Operations Manual - LAB.docx 3. (Section C.2 - Landfill gas Perimeter and Interior Monitoring, Page IV-12) a. The Drawing Sheets 2 & 3 are not available. Please provide the drawings. Response: The landfill gas perimeter and interior monitoring sheets will be included within the approved Landfill Gas Monitoring Plan. It is our intent to not have information in varying documents that will need to be updated should one change. b. (Section C.2 – Landfill Gas Perimeter and Interior Monitoring, Page IV-12) Orange County should include a list/table of all landfill gas monitoring wells. Response: A list of gas probes within the Compliance network shall be included within the approved Landfill Gas Monitoring Plan. It is our intent to not have two lists in varying documents that will need to be updated should one change. Please feel free to call or email should we need to discuss further. Sincerely, Draper Aden Associates 12/4/2019 C. Tyrus Clayton, Jr., PE Team Leader/Senior Associate Attachments: Revised 04-Operations Plan, dated December 2019. cc: file Robert Williams and Bruce Woody (OCSW) From:Luke Baker To:Chao, Ming-tai Cc:Robert Williams; Tyrus Clayton; Bruce Woody Subject:[External] RE: Orange County Landfill Environmental Monitoring Plan Date:Wednesday, December 04, 2019 1:27:47 PM Attachments:image001.png04-Operations Plan Rev 2019 1204.pdfLTR 19 1204 Chao - Response to Comments Operations Manual - LAB.pdf CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Ming, For your review, I have attached the revised Orange County operations plan, dated 12/4/2019. As well, a response letter to your comments dated 5/31/2019 is also included. Should you have any questions or comments, please do not hesitate to contact Tyrus Clayton or myself. Thank you, Luke BakerStaff Technician Draper Aden Associates Engineering • Surveying • Environmental ServicesLasting     Positive     Impact™ Phone: 919.827.0864 • Direct: 919.582.7288 • Mobile 910.723.5158 Web • Blog • Facebook • Twitter • LinkedIn From: Tyrus Clayton <tclayton@daa.com> Sent: Tuesday, November 26, 2019 8:59 AM To: Bruce Woody <bwoody@orangecountync.gov>; Chao, Ming-tai <ming.chao@ncdenr.gov> Cc: Robert Williams <rowilliams@orangecountync.gov> Subject: RE: Orange County Landfill Environmental Monitoring Plan Ming, We are inserting the County’s comments and changes to the operations plan this week. Please expect to see the revised document by December 3, 2019. C. Tyrus Clayton, Jr., PEGeotechnical/Construction Services Team LeaderSenior Associate Draper Aden Associates ATTENTION: Email sent from outside DAA. Engineering • Surveying • Environmental ServicesLasting     Positive     Impact™ Phone: 919.827.0864 • Direct Line: 919.827.0909 • Mobile 919.795.6302 Web • Blog • Facebook • Twitter • LinkedIn From: Bruce Woody <bwoody@orangecountync.gov> Sent: Friday, November 22, 2019 12:31 PM To: Chao, Ming-tai <ming.chao@ncdenr.gov> Cc: Tyrus Clayton <tclayton@daa.com>; Robert Williams <rowilliams@orangecountync.gov> Subject: RE: Orange County Landfill Environmental Monitoring Plan Ming, Good afternoon Thank you for this message. Draper Aden has received the final “language” for the operations plan from Orange County Solid Waste this week. They are currently completing the operations plan. By this message, I am asking Tyrus to give you a submission date for the operations plan. Let me know if you have any further concerns or comments, Thank you. Woody From: Chao, Ming-tai [mailto:ming.chao@ncdenr.gov] Sent: Friday, November 22, 2019 12:24 PMTo: Bruce WoodyCc: Ulishney, Adam; Kirchner, Chuck; Tyrus Clayton; Lane, ErvinSubject: [EXTERNAL MAIL!] Re: Orange County Landfill Environmental Monitoring Plan Hi Woody: I am piggy-bagging Ervin's message to stress that I have not received any responseto the 05/31/19 comments on the Operations Plan for non-disposal units in side the closed Orange County Landfill units, Permit No. 68-01. I sent out a follow-up email message on11/15/2019 to your and Tyrus' attention and have not received any response about the status of the requested document. I was told by Chuck that the closed HHW unit, located in the SouthLandfill Unit is used for a universal waste (fluorescent bulbs & tubes) storage site; this activity is proposing in the above-mentioned Operations Plan but is NOT approved yet. To avoid fromtangling any operation violation further for this illegal activity, please submit the complete Operations Plan ASAP. Thanks for your cooperation on this matter. Ming-Tai Chao, P.E. Environmental Engineer Permitting Branch, Solid Waste Section NCDEQ, Division of Waste Management (Mailing Address) 1646 Mail Service Center Raleigh, NC 27699-1646 (Street Address) Green Square, 217 West Jones Street Raleigh, NC 27603 Tel. 919-707-8251 ming.chao@ncdenr.gov http://portal.ncdenr.org/web/wm/sw E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulations. From: Lane, Ervin <ervin.lane@ncdenr.gov> Sent: Friday, November 22, 2019 11:42 AM To: bwoody@orangecountync.gov <bwoody@orangecountync.gov> Cc: Ulishney, Adam <adam.ulishney@ncdenr.gov>; Chao, Ming-tai <ming.chao@ncdenr.gov>; Kirchner, Chuck <chuck.kirchner@ncdenr.gov>; Tyrus Clayton <tclayton@daa.com> Subject: Orange County Landfill Environmental Monitoring Plan Mr. Woody, The Section’s response to the Environmental Monitoring Plan can be viewed in the link below: FID 1377384 Feel free to contact me if you have any additional questions or concerns.