9808_BlkCrkTS_ResponseComments_20221007

DocuSign Envelope ID: F83A9033-BEAB-46D1-B3F1-26E716E78FC8
SMITH GARDNER
ENGINEERS
October 7, 2022
Ms. Sherri Stanley
Permitting Branch Head
NC DEQ Division of Waste Management
217 W. Jones Street
Raleigh, NC 27603
sherri.stanley(ancdenr.gov
ABBRESS TEL WEB
14 N. Boylan Avenue, Raleigh NC 27603 919.828.0577 www.smithgardnerinc.com
RE: Black Creek Transfer Station (Permit No. 98-OBT)
Transfer Station Assessment
Response to Review Comments
Dear Ms. Stanley:
On behalf of GFL Environmental Inc., Smith Gardner, Inc. (S+G) is pleased to provide this
response to comments received from Ms. Donna Wilson via email correspondence dated July
11, 2022. The comments received are repeated below in italics followed by S+G's response in
bold.
1. Provide a response to the leachate collection drain system issue noted.
A field survey of the leachate collection system was conducted on September 23,
2022 through September 25, 2022. S+G anticipates receiving the results of the survey
in October. Once complete, the field survey will be used to help identify the most
appropriate solution for expanding the trench drain system and/or adding additional
infrastructure to convey leachate to the on -site leachate pump station.
Construction level documents will be developed by the end of the 2022 Calendar Year
with construction following in 2023. GFL Environmental Inc. will keep the Section
informed of the design and installation that is to follow. Per Rule 15A NCAC 13B
.0401(b)(3), GFL Environmental Inc. shall take actions to complete this task by July
11, 2025.
2. Please submit a revised operations plan as well as a closure plan with closure cost
estimates to include all information now required by 15A NCAC 13B . 0404, .0405, and
.014106.
Enclosed is an updated Operations Manual for the Black Creek Transfer Station
Facility. Revisions required to address the referenced rules along with other
general plan updates are summarized in the table below.

DocuSign Envelope ID: F83A9033-BEAB-46D1-B3F1-26E716E78FC8
Ms. Sherri Stanley
October 7, 2022
Page 2of2
Section
Revision
Section 1.2
Updated GFL and DEQ contact information.
(Contact Information)
Section 1.8
Revised to address new requirements.
(Litter Control)
Section 1.12
Added item for Transfer Station Cleaning
(Record Keeping Program)
and Maintenance Records.
Section 2.3.1
Revised to include new waste screening
(Waste Receiving and Inspection)
requirements.
Section 2.5.3
Revised to include use of leak -resistant
(Container Loading and Transport)
trailers to address new requirements.
Section 2.8
Section added to address new
(Operational Contingency Plan)
requirements.
Section 3.3
Revised section to follow similar plan at
(Leachate Management)
other GFL facilities.
Section 3.7
Section added to address new
(Site Cleaning and Maintenance)
requirements.
Section 4.0
Section added to address new
(Transfer Station Closure Plan)
requirements.
Figure 1 (Site Plan)
Revised to include general facility updates.
Appendix F
Appendix added to address new
(Transfer Station Closure Cost
requirements.
Estimate)
Please contact us at your earliest convenience should you have any questions, comments or
require further clarification.
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Attachment: DEQ Email with Comments (July 11, 2022)
Enclosure: Revised Operations Manual
CC: Donna Wilson, DWM; John College, DWM; Drew Hammonds, DWM
Sarah Moutos, DWM; Michael Lee, GFL Environmental Inc.; John Pfleger, GFL
Environmental Inc.; Crystal Slone, GFL Environmental Inc.

DocuSign Envelope ID: F83A9033-BEAB-46D1-B3F1-26E716E78FC8
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL SCOTT NORTH CAROLINA
Director Environmental Quality
July 11, 2022
Sent via email: [e-mail]
Mr. Michael Lee, Operations Supervisor
Black Creek Transfer Station
3031 Black Creek Road
Wilson, North Carolina 27893
SUBJECT: Transfer Station Assessment Report, Revised Operating Plan, Closure Plan, and
Closure Cost Estimates
Black Creek Transfer Station, Permit 9808T-TRANSFER-2000, Wilson County
Waste Industries, LLC, subsidiary of GFL
Dear Mr. Lee,
The State of North Carolina, Division of Waste Management, Solid Waste Section (Section) has
completed the review of the Transfer Station Assessment Report (report) for the above
referenced facility. The report was submitted by Smith Gardner Engineers on June 18, 2021, in
accordance with 15A North Carolina Administrative Code 13B .0401(b).
The intent of the report was to self -assess and demonstrate compliance with the rules in 15A
NCAC 13B .0400, readopted effective January 1, 2021, with a primary focus of vital
infrastructure at the facility as part of transitioning under the new rules and other life of site
permit requirements.
The findings of the report, based on an inspection, included: clogged leachate floor drains that
were cleared during the inspection, outside wall damage to two sides that were being repaired
during the inspection, and minor cracks in pavement.
In summary, the report recommended that the facility continue to monitor the concrete pad
pavement and outside panel walls for wear and damage, and repair as needed, and continue to
monitor the leachate drains to clear clogs.
Based upon our review, the Section agrees with the recommendation for continuing to monitor
and repair the pavement and outside panel wall damage, as needed.
However, the Section disagrees with the recommendation to continue to monitor the leachate
system for clogging and clear as needed. A review of inspection reports over the last 10 years
shows that clogging of the leachate drains is a continual problem. Copies of inspection reports
D E Q�� North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
NORTH CAROLINA -
gepartmem of EnvimnmeM l quay /`� 919.707.8200

DocuSign Envelope ID: F83A9033-BEAB-46D1-B3F1-26E716E78FC8
are attached. Operational maintenance alone has not shown to be an acceptable method of
compliance with leachate drainage and collection for this site. Inspection reports in 2013
indicated that replaced leachate piping in 2012 may have been too small. Based on these
findings and history, the Section finds the condition of the leachate collection drain system is
not as originally designed or constructed.
The Section requests that you provide a response to the leachate collection drain system issues
noted above.
Also, per the report recommendations, please submit a revised Operations Plan, Closure Plan,
and closure cost estimates to include all information now required by 15A NCAC
13B .0404, .0405 and .0406.
The requested leachate collection response, revised Operations Plan and Closure Plan, and cost
estimates should be submitted to the Section within 90 days of receiat of this letter.
The Section has established an electronic form for the submittal of Transfer Station closure cost
estimates and requests you submit the cost estimates in this manner using the following link:
https://edocs.deg.nc.gov/Forms/TransferStation FA.
The .0401 to .0406 Transfer Station Rules can be viewed at the link below, beginning on pdf
page 17:
http://reports.oah.state.nc.us/ncac/title%2015a%20-%20environmental%20guaIity/chapter%2013%20-
%20solid%20waste%20management/subchapter%20b/subchapter%20b%20rules.pdf
If you have any questions, please contact me at 919-707-8255 or [e-mail].
Sincerely,
Donna J. Wilson
Environmental Engineer
Solid Waste Section
Attachment
Email copy:
Crystal Slone, GFL
Lou J. Krasuski, Smith Gardner
Michael Brinchek, Smith Gardner
John College, SWS
Drew Hammonds, SWS
Sarah Moutos - SWS-ARO