34AA-PineyHillAcresLCIDLF_Comment_permitApp_FID1394562_20200320

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Chao, Ming-tai
To:Christopher Hay, EI, RSM
Cc:Heim, Susan A; Stanley, Sherri; [e-mail]
Subject:Comments on Renewal Application, Piney Hill Acres LCID, 34AA-LCID
Dear Mr. Hay:

The Solid Waste Section (SWS) completes a review of the permit renewal application (FID 1394337) received
on March 16, 2020 which contained a cover letter and a set of drawing (Figures 1 through 4). Because in the
03/16/2020 letter, you, on behalf of the permit holder- David Lee Lawson, LLC stated that the previous permit
application/operation plan for the above-referenced facility (DIN 23938) dated January 26, 2015 satisfies the
readopted Section Rule .1400, the SWS also reviewed the application to be sure that new compost operation
requirements are incorporated into the operation plan. Below are the comments on the submittals:

1. After reviewing the Operation Plan (DIN 23938), the SWS has several comments on the LCID landfill
operations:
i. The service area(s) of the landfill including the T&P and compost units is not available in the
permit application (DIN 23938). The Facility Compliance Inspection Reports stated the facility
service areas are Forsyth County and surrounding counties.
ii. The plan does not describe waste screening approaches to ensure that only permitted wastes can
be accepted at the landfill facility for recycling, composting and disposal at the LCID Landfill
unit. The screening and inspection should include the frequency and screening methods.
iii. (Section 1.5) Please use the correct abbreviation of the Division of Waste Management – DWM,
not DSWM.
iv. (Section 1.6) The landfill originally had 1.95-acre waste footprint. Since 2004, the waste
footprint was expanded to 3.9 acres, then to 6.43 acres in 2010 to present. In Section 1.1 of the
Operation Plan dated December 18, 2009 stated that “The zoning at the property was recently
changed Light Industrial – Special Use.” So, it looks like the landfill obtained a land special use
permit to construct and operate 6.43-acre LCID landfill from Winston-Salem City/ Forsyth
County Planning Board. This land special permit is not available in the SWS file/record system.
Please provide the copy of the land special use permit for the 6.43-acre LCID Landfill.
v. (Section 2) The permit application dated January 26, 2015 (DIN 23938) stated that the approved
documents (letter or permit) regarding the Erosion and Sediment Control (E&SC) measures for
the 6.43-acre land disturbance of landfill construction and operations was approved in previously
submittal. The approval document is available in the SWS file/record system; please provide a
copy of the approved document issued by the City of Winston-Salem or the NC Land Quality
Section.
vi. (Section 2.7) Applying water over wastes in the landfill is violating Rule 15A NCAC 13B
.0566(14); therefore, the narrative in this Section shall clearly state the water will not spray onto
wastes to suppress dust.
vii. (Sections 3.1 & 4.2) Add the following requirement to the Section:
a. The liquid form concretes are prohibited for disposal at the landfill.
b. Uncontaminated soil or earthen material must meet the “unrestricted use standards" -
meaning contaminant concentrations for each environmental medium that are acceptable for
all uses per NCGS 130A-310.65; and shall have any contaminant with a concentration less
than or equal to that in the NC Residential Health Base Preliminary Soil Remediation Goal
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(NC PSRG) which can be found in the web link:
https://files.nc.gov/ncdeq/Waste%20Management/DWM/SF/RiskBasedRemediation/updates-
december-2019/1.-2019-Dec-PSRG-Table.pdf
c. Wooden pallet is not acceptable for disposal. If the accepted wooden pallet being processed
for mulch, boiler fuel, or compost (considered as products), but the viable market or
beneficial use can’t be found, the above-mentioned products are considered as wastes which
CAN NOT BE DISPOSED in the LCIDLF (add this requirement to Section 4.5).
d. Asphalt as defined in NCGS 130A-294(m) may be acceptable for disposal.
viii. (Section 3.4)
a. According to Rule 15A NCAC 13B .0566(4) - Adequate soil cover shall be applied monthly,
or when the active area reaches one acre in size, whichever occurs first. Please correct the
first paragraph according to the rule requirement.
b. According to Rules 15A NCAC 13B .0566(5) & (7), the minimum of 1-foot cover soil shall
be placed over the wastes if the landfill is inactive for 120 calendar days, not 12 months or
more. The soil cover shall be vegetative according to the approved seeding plan to prevent
soil cover from erosion. Please rewrite the Section 3.4 accordingly.

ix. (Section 4.4) The first paragraph states “the treatment and processing facility shall not receive
more than 6,000 cubic yards of compost material per quarter. No more than 20,000 cubic yards
of compost may be stored per quarter.” The described operating capacity is:
a. Inconsistent with the descriptions in the 2nd paragraph of Section 5.1 “A large Type 1 facility
shall process or store more than 6,000 cubic yards of material per quarter.”
b. Not include the volume of non-compost material (such as soil & aggregate and scrap metals)
mentioned in Section 4.2 in the T&P unit. What is the maximum volume (including both raw
material and product) of soil and aggregate – concrete, rock, asphalt will be stockpiled at this
unit at any given day?

2. Regarding the operations of the existing Large Type 1 Compost unit, the March 16, 2020 letter stated
that the existing application - it is likely referring to Operation Plan dated January 26, 2015 (DIN
23938), meets the re-adopted composting Section Rule 1400 effective November 1, 2019. After
reviewing the Operation Plan (DIN 23938) against the new rule, the SWS has some comments and
requests stated below:
i. Per Rule 15A NCAC 13B. 1401(c), the new permit for the Compost Unit will have a 10-year
cycle. The SWS will assign the unit a new permit number to differentiate from the LCID
Landfill unit. Please provide the new unit/facility name.

ii. According to landfill disposal boundaries shown on Figures 2 through 4, the Treatment and
Process (T&P) Unit and the Compost Unit are operating on top of the inactive landfill disposal
area (overlapped color lines – purple, blue & pink) which is inconsistent with the statement in
the 2nd paragraph, Section 5.3 of the application (DIN 23938). The T&P Unit is prohibited
located on the top of the inactive landfill without prior approval from the SWS. Per Rule 15A
NCAC 13B .1404(7), the composite unit can NOT be located and operated over the closed-out
disposal area unless a pad as defined in Rule 15A NCAC 13B .1404 (a)(10)(C) that is designed
and constructed to protect the disposal area cap from being disturbed and there shall be no runoff
from the pad onto the cap or side slopes of the closed out area. Therefore, David Lee Lawson,
LLC must
a. Relocate the T&P and Composite Units to the area outside the inactive area of the LCID
Landfill. The set of revised figures with revised acreage of each unit should be provided in
the Permit Application. Or
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b. Submit the plan of design and construction (Construction Quality Control Plan & Technical
Specification) of the rule-required pad.

iii. The permit application dated January 26, 2015 (DIN 23938) did not provide the approved
documents (letter or permit) regarding the Erosion and Sediment Control (E&SC) measures
associated with the operations of the T&P and Large Type 1 Compost Unit. The requirement of
approval of E&SC is due to the disturbance area of the T&P and composting operation is much
greater than that in previously approved application. Please provide a copy of the permit or
approval letter per Rules 15A NCAC 13B .1404(c)(2) & .1406(4).

iv. Per Rules 15A NCAC 13B .0302 and .1404(c)(2) & (3), the plan shall provide measures to avoid
or mitigate generation of leachate (Section 2.3), dust (Section 2.7), any nuisance (odor) in the
course of waste process and treatment, such as – “No grinding of wastes shall take place in the
raining or windy days and The composting piles or windrows shall not be turned on windy
days.” Or provide more info or elaboration of what has been designed and implemented in
operations to minimize odors at the property boundaries (Section 5.3-item 4).

v. (Sections 4.2 & 4.4) The Section states pallet is not acceptable waste; but Section 4.4 states
pallets will be collected and ground for mulch and boiler fuel. The Facility Compliance
Inspection Reports stated the lumber and pallet will not be for compost feedstock. Please provide
the consistency of the waste stream for the T&P unit and the Compost Unit.

vi. Section 5, the first Paragraph states that Mr. Aaron King, Land Use Coordinator with Planning &
Development Services for the City of Winston-Salem confirmed that a Type 1 Compost Facility
would be allowed at the property under the current zoning (LI-S). Please provide a written
approval letter from the Land Use Coordinator with Planning & Development Services for the
City of Winston-Salem per Rules 15A NCAC 13B .0301(2) and .1405(4).

vii. (Section 5.1) The last sentence is misleading. Please state that non-compostable solid waste and
unacceptable compost but acceptable waste stream for disposal at the LCID landfill (as stated in
Section 3.1) can be disposed at the LCID landfill. Other non-conformance or prohibited wastes
(per Rule 15A NCAC 13B .1403) received incidentally must be documented, reported (by notify
the Division within 24 hours of attempted disposal of any waste the landfill is not permitted to
receive, including waste from outside the area the landfill is permitted to serve), properly
temporarily stored in the covered container(s) and disposal of according to the Federal, State or
local laws.

viii. (Section 5.4) The 2nd paragraph states that the compost piles will be treated with passive compost
methods, unless aeration is necessary to maintain an elevated temperature or reduce odor. Please
elaborate
a. The trigging temperature to aerate the compost pile.
b. The protocols to take temperature measurements including locations, frequencies, tools to be
used (including calibration requirements), and record keep requirements.
c. The prevention measures to avoid compost spontaneous combustion.
d. Thermometer calibration requirements per Rule 15A NCAC 13b .1406(10).

(Section 5.4) The testing requirements for a compost from Type 1 Facility is incorrect. Per Rule
15A NCAC 13B .1407(a): 
Compost or mulch that is produced at a Type 1 facility, is free from offensive odor, contains no
sharp particles, and, for compost, has met the temperature requirements in Rule .1406(11) of this
Section shall be classified Grade A and have unrestricted application and distribution. Compost
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analytical testing shall not be required for Type 1 compost if temperature requirements in Rule
.1406(11) of this Section have been met and documented. 
Please delete the incorrect paragraph in this Section,
ix. Descriptions the operator training requirements per Rule 15A NCAC 13B .1406(19) and the
operator current training status are required in the plan.
x. Descriptions of the compost unit/facility closure requirements per Rule 15A NCAC 13B .1410
are required in the plan.

3. The May 13, 2003 permit application contained a drawing which has the approval stamp with dates and
signatures under a seal of compliance with the Erosion Control Ordinance adopted by the Forsyth
County Commissioner, effective dated July 1, 1973. Please provide a copy of the approval document to
demonstrate that construction and operation of current 6.43-acre LCID Landfill & operations of T&P
and compost unit [referring Section 5.3 – General Permit No. NCGS240000 (DIN 23938)] are in
compliance with the Erosion Control Ordinance adopted by the Forsyth County Commissioner, effective
dated July 1, 1973 & Rule 15A NCAC 13B .1406.

3. Please provide the correct and final acreages of the landfill waste footprint. There are several different
acreages in the permit applications – current and previous ones.
Date of Application Waste Footprint
(acres)
Document ID Note
March 13, 2020 5.46 1394337 Figures 2 - 4
January 26, 2015 5.31 23938 Figures 2 - 4
December 18, 2009 6.425 9277 Figures 2 - 4

5. To avoid confusion, please clarify the following notes in Figures 2 through 4 and show the consistent
acreage of each unit.
i. Total Facility = 10.15 +/-acres. But sum up the data from figures (Compost/T&P units) 5.79 +
(Landfill Waste Footprint) (2.23 +3.23) = 11.25 acres.
ii. The existing LCID landfill =2.88 +/-acres; Future LCID Landfill = 2.23 +/-acres; and Proposed
LCID Landfill = 0.17 +/-acres. The total acreage = 2.88+2.23+0.17 = 5.28 acres. But sum up
the data from figures is 5.46 acres (Landfill Waste Footprint = 2.23 +3.23).
iii. The T&P = 5.41 acres which is inconsistent with the number of 5.79 acres in the figures.

6. At the “Note Field” in figures, please add the legal agreement dated 23 May 2002 between David L.
Lawson and NCDOT that the stormwater pipe under Piney Grove Road shall be closed. Add the date
that the pipe has been closed. Identify the pipe location on the figures.

Please submit a revised operations plan which incorporates the responses to the above-mentioned comments. If
you have any questions of the comments please contact me or Susan Heim at 336-776-9672. Thanks.

 Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]
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From: Christopher Hay, EI, RSM <[e-mail]>  
Sent: Monday, March 16, 2020 9:51 AM 
To: Chao, Ming‐tai <[e-mail]> 
Cc: Heim, Susan A <[e-mail]>; Stanley, Sherri <[e-mail]>; [e-mail] 
Subject: RE: [External] Piney Hill Acres LCID ‐ NC Solid Waste Permit No. 34AA‐LCID Renewal 

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to 
[e-mail] 

Mr. Chao, 

Please review the revised permit renewal request for the referenced facility. Please let me know if you have any 
questions or require additional information. 

Christopher Hay, EI, RSM
Regional Operations Manager
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EnviroTrac Ltd.
phone: [phone] | mobile: [phone] | email: [e-mail]
7343 West Friendly Ave
Suite J Greensboro, NC 27410 | https://envirotrac.com [envirotrac.com]

From: Chao, Ming‐tai <[e-mail]>  
Sent: Thursday, March 05, 2020 10:53 AM 
To: Christopher Hay, EI, RSM <[e-mail]> 
Cc: Heim, Susan A <[e-mail]>; Stanley, Sherri <[e-mail]>; [e-mail] 
Subject: FW: [External] Piney Hill Acres LCID ‐ NC Solid Waste Permit No. 34AA‐LCID Renewal 

Dear Mr. Hay:

The Solid Waste Section receives the permit renewal application today. Since the compost rule – Section Rule
1400 is readopted and effective November 1, 2019, it is the permittee’s responsibility to re-examine the exiting
permit application to ensure that the application meets the current rule requirements, not just drawings
alone. The web link to the current rules is
http://reports.oah.state.nc.us/ncac.asp?folderName=\Title%2015A%20-
%20Environmental%20Quality\Chapter%2013%20-%20Solid%20Waste%20Management
[reports.oah.state.nc.us]. Additionally, the landfill capacity including the in-place waste volume and remaining
capacity including the final cover volume shall be provided in the renewal application. If anything of the waste
operations will be changed or has been done and be continued in the future, but not included in the previous
permit application, please incorporate the changes or modifications into the renewal application. Please review
the past five years audit report for the facility, any requested improvement in the reports shall be incorporated
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into the permit renewal applications. The Solid Waste Section is looking forward to receiving the complete
permit renewal application.

From: Christopher Hay, EI, RSM <[e-mail]>  
Sent: Thursday, March 05, 2020 10:28 AM 
To: Chao, Ming‐tai <[e-mail]> 
Cc: David Lawson ([e-mail]) <[e-mail]> 
Subject: [External] Piney Hill Acres LCID ‐ NC Solid Waste Permit No. 34AA‐LCID Renewal 

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to 
[e-mail] 

Mr. Chao, 

Please review the attached letter and drawings requesting permit renewal without modification for the referenced 
facility. Please let me know if you have any questions or require additional information. 
Christopher Hay, EI, RSM
Regional Operations Manager
[facebook.com] [linkedin.com] 

EnviroTrac Ltd.
phone: [phone] | mobile: [phone] | email: [e-mail]
7343 West Friendly Ave
Suite J Greensboro, NC 27410 | https://envirotrac.com [envirotrac.com]

 Ming-Tai, Chao
Environmental Engineer, Solid Waste Section
Division of Waste Management
North Carolina Department of Environmental Quality
919.707-8251 (Office)
[e-mail]