HomeMy WebLinkAbout9606_WayneMSWLFComment_DIN25782_20160318.pdf
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
MICHAEL SCOTT
Acting Director
Solid Waste Section
March 18, 2016
Mr. Tim Rogers
Solid Waste Director
460 B South Landfill Road
Dudley, NC 28333
Re: Comments on Permit Amendment Application (Permit Application)
Wayne County Landfill Facility, Wayne County, North Carolina
Permit No. 9606-MSWLF-1998, Document ID No. (DIN) 25782
Dear Mr. Rogers:
On January 13, 2016 the Division Waste Management (DWM), Solid Waste Section (SWS)
received the Permit Amendment Application titled as:
“Amendment to Permit – Municipal Solid Waste And Construction And Demolition
Landfill Facilities.” Dated January 2016. Prepared by Municipal Engineering Services
Company, P.A. (MESCO) [DIN 25494].
Wayne County (the County) submitted the Permit Amendment Application for requesting an
approval for a continued operation of the following landfill units at Wayne County Landfill
Facility:
1. Wayne County Municipal Solid Waste Landfill (MSWLF) unit, Permit No. 9606-
MSWLF-1998, Phases 1, 2, 3, and 4. The MSWLF-Phase 4 is a vertical expansion.
2. Wayne County Construction and Demolition Debris Landfill (C&DLF) unit, 9601-
CDLF-1997, Phases 1, 2, and 3. The C&DLF is located on top of the closed, unlined
MSWLF (Unit 2), which is subject to the ongoing groundwater corrective action.
3. Wayne County Land Clearing and Inert Debris Landfill (LCDILF) unit and other non-
disposal solid waste management units.
Pursuant to the North Carolina Solid Waste Management Rules (Rule) 15A NCAC 13B, Article
9 of the Chapter 130A of the North Carolina General Statutes (NCGS 130A-290, et seq.), and the
permit conditions for landfill units (DIN 19025 & 16640), the SWS has conduct a review on the
Permit Amendment Application. The comments on the Permit Amendment Application are
stated below. Your timely responses to the comments will expedite the completion of the
reviewing processes.
General
1. The North Carolina Department of Environmental and Natural Resources (DENR)
officially became the Department of Environmental Quality (DEQ) on Sept. 18, 2015
Mr. Tim Rogers
March 18, 2016
DIN 25782
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when Governor McCrory signed the 2015-2016 state budget into law. Please use the
correct department name or its acronym NCDEQ throughout the Permit Application.
MSWLF Unit (9606-MSWLF-1998)
Engineering Plan
2. (Section 1.1) According to the Permit to Construct Application for the MSWLF – Phase 3
(DIN 14016) approved on June 13, 2011, the combined capacity of Phases 1 through 3 is
2,327,598 cubic yards (CY) which is summarized below:
Phase Acreage Air Space (CY)
1 23 1,100,000
2 21 685,711
3 21 541,887
Total 65 2,327,598
However, the Phasing Table in Section 1.1 (on Page 7) of the Permit Application states
the combined capacity of Phases 1 through 3 is 2,538,681 CY.
i. Is the landfill unit overfilled than the approved capacity of 2,327,598 CY?
ii. What is the in-place waste volume (in CY) of the MSWLF unit according to the
latest survey data in 2015?
3. (Section 1.1) As described in the Permit to Construct Application for the MSWLF –
Phase 3 (DIN 14016) approved on June 13, 2011, the MSWLF unit has the approved total
capacity of 5,365,695 CY, which is defined as the volume measured between the bottom
of waste (or the top of the protective cover of landfill base system) and the top of the final
cover of the landfill unit including the volume of daily cover and final cover system. To
avoid any confusion, please define the approved total capacity in the Section.
4. (Section 1.1.7) Please add the following requirements to the subsection:
i. The 20-year leachate disposal agreement – Utility Agreement between the County
of Wayne and the City of Goldsboro will expire on March 3, 2020.
ii. The County must submit the SWS a copy of the renewal leachate disposal
agreement on or before March 3, 2020 to retain the life-of-site permit of the
MSWLF unit.
Operations Plan
5. (Section 2.1, On Page 40) Please address the following concerns:
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March 18, 2016
DIN 25782
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i. The program for corrective actions of leachate breakouts is placed in Section 2.8,
Appendix VI of the Permit Application. Please correct the typo.
ii. (Paragraph 8) Please provide the inspection frequency for the leachate breakouts,
both routine and non-schedule inspections. The record keeping requirement of
the inspection record.
6. (Section 2.2) On August 09, 2013 the SWS approved (DIN 19484) the County to operate
the several non-disposal solid waste management units inside the Wayne County Landfill
Facility according to the approved Operations Plan titled “ Operations Plan for: Sorting
Tear-off Asphalt Shingles for Recycling, Passive Composting In Borrow Pit #1, and Inert
Debris Storage & Processing in Borrow Pit #1 (DIN 19483). If the County intends to
continued operation of these units, please provide the revised or updated Operations Plan;
the location of each active unit must be shown the Facility Plan drawing.
7. (Section 2.2.1, On Page 44) Should the mobile homes that originate in Wayne County,
rather than Alamance County be acceptable for disposal or recycling at the landfill
facility? Please clarify.
8. (Section 2.2.7) Please provide additional information and address some concerns of the
Water Quality Monitoring Plan.
i. Add the locations of the eleven (11) groundwater monitoring wells and three (3)
surface water monitoring points to the operation plan drawings.
ii. The monitoring well MW-1 was plugged and abandoned (P&A) in June 14, 2013.
The P&A record (GW-30 form) must be submitted to the SWS for a review and
approval.
iii. Since the well MW-1R is replacing the MW-1, please provide the correct info
throughout this Section.
9. (Section 2.2.12 Leachate Management Plan) Since leachate circulation is not proposed in
the Permit Application, please state the generated leachate from the landfill unit will not
be circulated.
10. (Section 2.2.13) The landfill gas gathered from the gas collection and control system is
treating and generating electricity at the on-site Landfill Gas To Energy Unit. Please
provide the following information of this unit:
i. The location of the unit including the flare which must be shown on the Facility
Plan drawings.
ii. The ownership of the unit.
iii. The current and valid NC Air Quality Permit for the flare system and
engine/generator unit(s).
Mr. Tim Rogers
March 18, 2016
DIN 25782
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11. (Section 2.5/Appendix III – Explosive Gas Control Plan – MSW & C&D) Since the SWS
doesn’t approve the new gas monitoring plan (referred email messages dated the March
14, 2014 [DIN 20729] & February 22, 2016 from Christin Ritter, the SWS
Hydrogeologist to the County’s representatives), the existing 25 gas monitoring wells
installed around the landfill facility shall not be removed from the operation plan
drawings. Please add all gas probes/wells to the operations plan drawings.
12. (Section 2.10 Engineering /Operations Drawings) Please make corrections on the
following drawings:
i. (Drawing No. E2/Sheet No. 4 of 10)
a. Mark/note the MSWLF-Phase 4 on the drawing.
b. Are the fill contours of the in-place wastes for both MSWLF unit & C&DLF
unit shown on the drawing generated from the latest survey result in 2015? If
not, add the fill contours from the latest survey result in 2015 to the drawing.
ii. (Drawing No. E4/Sheet No. 6 of 10)
a. The drainage net shown in the “Typical Methane Gas Collection Well to Vent
Conversion Detail) is 250 mil double bonded geosynthetic material which is
inconsistent with that specified in the Section 3.6 (on Page 96) of the Closure
Plan of the MSWLF unit .
b. The existing “Typical Cap Closure Details” are associated with the MSWLF
unit. Please note the details are associated with the MSWLF unit.
c. Add the details of the final closure cover system and the passive venting
system of the C&DLF unit to the drawing which must be consistent with the
specification/descriptions described in the Closure Plan of the C&DLF unit.
iii. (Drawing No. E8/Sheet No. 10 of 10)
a. To avoid confusion, the “existing grade’ should be the original grade prior to
construction the landfill unit such as the one shown on Station 21+00 (MSW).
The so call “existing grade” on other cross-sections should be the fill grades
of in-place wastes which must be consistent with the latest survey result in
2015. Please replace the “existing grade” for a proper term for both MSWLF
& C&DLF units.
b. The intermediate fill grades for Phase 4 at Station 16+00 (MSW) is
approximately ranging from 194 feet (at Station 8+20) to 190 feet (at Station
13+20) and to 180 feet (at station 13+75). The cross-section - Station 16+00
(MSW) is not consistent with the grades shown on Drawing No. E2/Sheet No.
4 of 10.
Mr. Tim Rogers
March 18, 2016
DIN 25782
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Closure and Post Closure Plans
13. (Section 3.1) Please provide the following rule-required info:
i. Please state that the proposed post-settlement the slopes of the side and deck
portions of the final cover system will be a minimum of 5 percent and a maximum
of 25 percent [Rule 15A NCAC 13B .1627(c)(3)(A)]. The specific ranges of the
surface slopes were approved in the PTC Application - Phase 3 (DIN 14016).
ii. Please also provide the maximum inventory of wastes, in the latest surveyed
volume in cubic yard, of ever on-sit over the active life of the landfill facility
[Rule 15A NCAC 13B .1629(b)(1)(C)].
14. (Section 3.6) This section indicates that the average annual discharge generated from the
HELP model from 2004 Application is used for calculating the flow capacity of the
proposed drainage net; however, the SWS has no record indicating that the referenced
model results exist. Please provide the referenced HELP Model results.
15. (Section 3.7) Please add the typical details of the proposed closure venting system to the
closure plan drawing.
16. (Section 4.1, Third paragraph) The landfill facility doesn’t have any leachate collection
tank, but a lagoon/surface impoundment to store leachate generated from the landfill
units. Please make the correction to the description.
C&DLF Unit (9601-CDLF-1997)
Engineering Plan
17. (Section 1.1, General) The approved total gross capacity for the C&DLF unit is
2,736,883 CY, consisting of air space of 2,478,749 CY and the final cover system with a
volume of 258,134 CY. The gross capacity is defined in the Rule A NCAC 13B
.0537(e)(2)(B). To avoid any confusion, please
i. State the C&DLF facility has a permitted gross capacity, not air space capacity, of
2,736,883 CY consistent with the described Pashing Table on Page 111.
ii. Provide the estimate of maximum inventory of C&D waste (in-placed waste
estimate) on-site in cubic yard based on the latest survey data (in 2015).
18. (Section 1.1.1) Please specify the thickness of each of the soil liner and the erosive later
shall be measured perpendicular to the slope surface.
19. (Section 1.2) Please provide additional info of the LCIDLF unit:
i. Describe the bottom elevation of the waste is at least four (4) feet above the
seasonal high water table according to February 2012 Evaluation Report [Rule
15A NCAC 13B .0565(1)(b).
Mr. Tim Rogers
March 18, 2016
DIN 25782
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ii. Describe the extent of the waste footprint (in acre) of the LCIDLF [Rule 15. 15A
NCAC 13B .0565(3)(h)].
iii. Describe the proposed excavation, grading, and/or final contours of the landfill
slopes [Rule 15. 15A NCAC 13B .0565(3)(j)].
iv. Describe the approved total capacity of the LCIDLF unit is 41,716 CY which
consists of air space of 35,263 CY and final cover system of 6,453 CY.
v. Describe the space utilization of the Phase 1 – the in-place waste volume and
remaining capacity (in cubic yard).
Operations Plan
20. The groundwater underneath the unlined, closed MSWLF unit which is overlain by the
active C&DLF unit is impacted by waste disposal activities; the implementation of the
approved corrective action program to restore the groundwater quality is required by the
Rule 15A NCAC 13B .0547(4), the Corrective Action Plan (DIN 8821), and the Permit
Conditions stipulated in the Permit to Operate dated August 27, 2012 (DIN 16640). The
Operation Plan must provide the following information and/or document.
i. Please provide the chronologic descriptions of the Corrective Action Plan (CAP)
including the Sampling and Analysis Plan (SAP), the supplement, and/or revision
since the CAP approval date of October 22, 2009. The approved documents or
approval letters including the document identification number (DIN), date, and
etc.
ii. Provide the findings and results according to the latest Corrective Action
Evaluation Report (CAER). The CAER must be appended to the permit
amendment application [Permit Condition No. 1, Attachment 3, of the Permit
(DIN 16640)].
iii. The cost estimates for completion of the groundwater restoration/remediation
based on the latest approved CAP. This cost for completion of the CAP must be a
portion of the post-closure cost estimates.
21. The landfill gas collection and control system (LFGCCS) are installed and operated in the
unlined, closed MSWLF unit, overlaid by the active C&DLF. Therefore,
i. The Operations Plan should describe the requirements of the operation,
maintenance, inspection and decommission of the LFGCCS.
ii. The copy of the current, valid NC Air Quality permit No. 08885T03 shall be
appended to the Operations Plan.
22. (Section 2.2) Please correct the typos and additional information:
i. (Paragraph 1 - Wates Acceptance and Disposal Requirements) The Alamance
County mentioned in the “item j” is likely a typographic error.
Mr. Tim Rogers
March 18, 2016
DIN 25782
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ii. (Paragraph 2 –Cover Material Requirements) The referenced Paragraph 10 for
record keeping requirement is likely a typo.
iii. (Paragraph 9 e.) Please address the following concerns regarding the leachate
breakout:
a. In addition to the weekly inspection, the non-schedule inspections should be
executed after a major storm event or a drenched raining season pass.
b. The inspection log/record should be placed in the facility operating record.
c. Section 2.8/Appendix VI -The Corrective Action for Leachate Break-Outs of
the Part 1 MSWLF might be applicable for the C&DLF unit as well. If so,
please place the reference of Section 2.8/Appendix VI in the Paragraph 9.
Closure and Post Closure Plans
23. (Section 3.1) Please provide the additional information or correct the typographic errors:
i. The estimated schedule of the C&DLF closure is approximately 24 years
according to the Air Space Calculation in Appendix A. Please correct the typo.
ii. Please also provide the maximum inventory of wastes, in the latest surveyed
volume in cubic yard, of ever on-sit over the active life of the landfill facility
[Rule 15A NCAC 13B .0543(d)(3)].
24. (Section 3.2) The largest area currently requiring a cap system for the C&DLF unit on top
of the unlined, closed MSWLF (unit 2) shall be 40 acres according to Rule 15A NCAC
13B .0547(4) and consistent with the Section 3.7 – Closure Cost Estimates. Please revise
the Section accordingly.
25. (Section 3.5) Please provide additional information regarding the proposed gas venting
system:
i. Please provide the total number of the gas vents to be installed over the 40-acre
closure cover system (the standard rate/frequency is one vent per acre).
ii. Please provide a typical detail of the proposed venting system to the Closure Plan
drawings.
26. (Section 3.7) The costs associated with installation of the passive gas venting system
described in the Section 3.5 is not completely included in the closure cost estimates.
i. Please add the costs for material & labor for geotextile, stone, and trenching &
laying piping, and revise the final cost for the closure activities.
ii. Please note that the number of vents must be consistent with the response to the
Comment No. 25.
Mr. Tim Rogers
March 18, 2016
DIN 25782
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27. (Section 4.1) Please describe the requirements of permit, operation, maintenance, &
decommissioning of the existing LFGCCS at the landfill unit during the course of 30-
year post-closure period.
28. (Section 4.2) Please add the cost for completing the approved Corrective Action Plan to
restore the groundwater quality underneath the unlined, closed MSWLF unit [referring
the Comment No. 20.iii. Please note that the aforementioned costs are excluded from the
two million dollar – PACA/ NCGS 130A 295.2(h)].
Appendix A – Revised Facility Plan Drawings
29. Please add the following information to the drawing [Rules 15A NCAC 13B .0537(d) &
.1619(d)]:
i. (Drawing No. F1/Sheet No. 3 of 8) Locations of the passive composting unit, inert
debris processing & storage unit, tear-off shingle storage unit, and landfill gas to
energy unit/flare station.
ii. (Drawing No. F2/Sheet No. 4 of 8) Mark/note the MSWLF-Phase 4 on the
drawing.
Sincerely,
Ming-Tai Chao, P.E.
Environmental Engineer
Division of Waste Management, NCDEQ
cc:
Wayne Sullivan, MESCO Ed Mussler, Permitting Branch Supervisor
Christine Ritter, DWM Wes Hare, DWM
Central File