GCIA GCSWMP Amendment Request Red Size

June 9, 2020

The Gloucester County Improvement Authority Office of Recycling 503 Monroeville Road, Swedesboro, NJ 08085

Re: Gloucester County Utilities Authority / Gloucester County Improvement Authority Amendment to Gloucester County Solid Waste Management Plan (GCSWMP) Our File No. 0800M060

Sir/Madam,

Remington & Vernick Engineers (RVE) is submitting this request on behalf of the Gloucester County Improvement Authority (GCIA) and the Gloucester County Utilities Authority (GCUA), to amend the Gloucester County Solid Waste Management Plan (SWMP) to include the use of non- hazardous dry sewage sludge (Classified as ID 12) as part of a blend with other authorized alternative cover material for use as daily cover at the GCIA landfill facility.

RVE has been working with GCIA and GCUA to get NJDEP (Department) approval to evaluate the effectiveness of using biosolids as part of a blend with soil or other authorized alternative cover materials for use as a daily cover material. The biosolids are being generated at GCUA, a sister agency, as part of sludge handling during the wastewater treatment process.

GCUA operates a Publicly Owned Treatment Works (POTW) to treat wastewater generated from domestic and industrial sources in the residential and commercial areas of southern New Jersey. The POTW is located at 2 Paradise Road, Thorofare, New Jersey, 08066 in West Deptford Township.

The GCUA continues to seek new beneficial use options to effectively manage the sludge generated at its facility. Significant cost savings may be possible through reduced transportation distances, logistics, and sludge management costs, if the biosolids generated at GCUA can be used beneficially at GCIA as an alternative daily cover. Besides cost reduction for GCUA, beneficial use of biosolids as daily cover at GCIA offers other potential benefits such as:

• Reduced need for traditional clean soil resources; • Lower cost to meet landfill cover needs; • Create a foundation for opportunities for using biosolids to fulfill cover needs at other landfills; and • Maintain the highest economic benefit of biosolids management within New Jersey.

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Page 2 June 9, 2020 Gloucester County Utilities Authority 0800M060 Gloucester County Solid Waste Management Plan Amendment

In accordance with the Department’s Division of Solid & Hazardous Waste Regulations and Technical Manuals, the use of an alternative material for daily landfill cover must be approved as a modification to a Sanitary Landfill Facility permit. Since biosolids is not a soil and is a non- traditional non-hazardous cover material classified as ID 12 (dry sewage sludge), the Department provides that its use may be evaluated in accordance with the requirements for Research Development & Demonstration (RD&D) projects outlined in N.J.A.C. 7:26-2A.8(b)19.

The Department requested GCIA to establish and submit a RD&D protocol to evaluate the use of biosolids as alternative cover material. The RD&D application was submitted by RVE on October 27, 2017 and was subsequently approved by the Department on April 11, 2018. Correspondence between GCIA and the Department, the RD&D application, and the Department approval are included as Attachment A for reference. The RD&D application contains all the information requested in the Gloucester County Procedures and guidelines for Gloucester County Waste Management Plan inclusion of recycling and solid waste facilities.

A modification to the existing RD&D application was submitted in September 2018 and was subsequently approved by the Department on January 23, 2020. Per the approval, permission was granted to GCUA to conduct the RD&D project using two (2) digested biosolids streams. The approval allows GCIA to accept no more than 100 tons of digested GCUA biosolids per day. The GCUA biosolids treated with or without the proprietary O’Rege process are accepted on a daily basis and are currently applied as a blended material mixed with soil or other authorized alternative cover material such as ID 27 contaminated soil, automobile shredder residue or recycled glass aggregate. The modified RD&D application along with relevant NJDEP correspondence is included as Attachment B for reference.

Biosolids generated at GCUA have been evaluated for use as alternate daily cover at GCIA since April 2018. Based on the observations by GCIA staff and RVE representatives in accordance with the RD&D, the blended biosolids material has provided adequate cover. There were no observations of exposed waste material; evidence of any vectors, rodents or burrows; litter from covered landfill surfaces; erosion caused by rain or wind; or dust generation. There were no observations of ponding or any evidence of excessive runoff that would result from any impervious cover material. There were no observations of fire or any evidence suggesting the biosolids blended cover will not provide an adequate fire break.

Based on the observations above, it is our conclusion that the biosolids blend provided a suitable and adequate daily cover meeting the performance criteria set forth in the Department’s regulations (N.J.A.C. 7:26-2A.8(b)15i through v.

RVE requests that the Gloucester County SWMP be modified to include the use of non-hazardous dry sewage sludge (Classified as ID 12) as part of a blend with other authorized alternative cover material for use as daily cover at the GCIA landfill facility. Subsequent to the SWMP amendment, RVE will submit a permit modification application to the Department to modify GCIA’s solid waste

Page 3 June 9, 2020 Gloucester County Utilities Authority 0800M060 Gloucester County Solid Waste Management Plan Amendment operating permit to include the use of non-hazardous dry sewage sludge blend as alternate daily cover.

Please contact Gautam Patwardhan at [email protected] or by phone at (856) 685- 6213 should you have any questions or need more information.

Sincerely, REMINGTON & VERNICK ENGINEERS

Gautam S. Patwardhan, PhD., P.E.

Cc: DKY

Attachment A

RD&D Application – October 2017 DEP Approval – April 2018

ATTACHMENT – RD&D APPLICATION

GLOUCESTER COUNTY IMPROVEMENT AUTHORITY

GLOUCESTER COUNTY LANDFILL

Research Development & Demonstration (RD&D) Application

October 2017

Prepared for Gloucester County Improvement Authority, West Deptford, NJ

Prepared By

232 Kings Highway East, Haddonfield, NJ 08033 TABLE OF CONTENTS

INTRODUCTION ...... 1

BACKGROUND AND PROJECT INFORMATION ...... 2 Project Sponsor ...... 2 Biosolids Product Generator Information ...... 2 Biosolids Product Storage and Transportation ...... 2 Environmental, Engineering Consulting and Support Services ...... 3 Contact Information ...... 3

RD&D OVERVIEW AND OBJECTIVES ...... 5 Background ...... 5 Objectives ...... 5 Biosolids Product Physical and Analytical Properties ...... 6 Scope ...... 6 RD&D Demonstration Requirements ...... 7 1) Alternative Landfill Cover Requirements [N.J.A.C. 7:26-2A.8(b)15] ...... 7 2) Alternative Cover Performance Requirements [N.J.A.C. 7:26-2A.8(b)16] ...... 10 Soil-like Material Laboratory Testing Requirements [N.J.A.C. 7:26- ...... 12 3) 2A.8(b)17] ...... 12 RD&D Analytical Data Limitations ...... 12

RD&D IMPLEMENTATION AND MANAGEMENT ...... 13 Biosolids Product Acceptance/Storage ...... 13 Daily Cover Placement...... 13

RECORDKEEPING AND REPORTING ...... 14 Recordkeeping ...... 14 Laboratory Testing ...... 14 Reporting ...... 15

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\GCIA RD&D Application.docx I APPENDICES

APPENDIX I – Site Plan

APPENDIX II – Correspondence

APPENDIX III – Cover Material Inspection Form

APPENDIX IV – Particle Size Distribution Results

ADPPENDIX V – Process Flow Diagram

APPENDIX VI – GCIA Authorization Letter

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\GCIA RD&D Application.docx II INTRODUCTION

The Gloucester County Solid Waste Complex is owned and operated by the Gloucester County Improvement Authority (GCIA). Located in South Harrison Township, the Solid Waste Complex is a sanitary landfill situated on a 540-acre tract of land. Currently the active landfill and supporting structures utilize 20 percent of the available area, the balance of the site remains undeveloped with parts used as a grassland bird habitat, for storm water management and a visual buffer. A Site Plan is included as Appendix .

GCIA is seeking a Research Development and Demonstration (RD&D) approval from NJDEP (Department) to evaluate the effectiveness of using biosolids as part of a blend with soil or other authorized alternative cover materials for use as a daily cover material. The biosolids will be generated at the Gloucester County Utilities Authority (GCUA), a sister agency, as part of sludge handling during the wastewater treatment process. The effectiveness of the alternative daily cover (biosolids) will be evaluated over a twelve-month (12) period by monitoring its use under varying operational and weather conditions. Should the RD&D provide favorable results, GCIA anticipates seeking longer term approval through a permit modification.

In accordance with the Department’s Division of Solid & Hazardous Waste Regulations and Technical Manuals, the use of an alternative material for daily landfill cover must be approved as a modification to a Sanitary Landfill Facility permit. Since biosolids is not a soil and is a non- traditional cover material, the Department provides that its use may be evaluated in accordance with the requirements for RD&D projects outlined in N.J.A.C. 7:26-2A.8(b)19.

The Department requested GCIA to establish and submit a RD&D protocol to evaluate the use of biosolids as alternative cover material. Correspondence between GCIA and the Department, including a copy of the Departments request is included as Appendix II. This application, prepared on behalf of GCIA, by Remington & Vernick Engineers (RVE), serves to fulfill that request.

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NJDEP regulations applicable to the management of solid waste provide for an exemption from a full facility permit for RD&D projects to test and evaluate new or innovative technology or new innovative operational process modifications made to existing solid waste facilities or operations. The regulations, published at N.J.A.C. 7:26-1.7(f), require that a RD&D must be designed, constructed and operated consistent with applicable environmental statutes, rules, permits, approvals or orders.

PROJECT SPONSOR

GCIA is seeking a RD&D approval from the NJDEP to evaluate the effectiveness of using sludge derived biosolids as part of a blend with soil or other authorized alternative cover materials for use as a daily cover material. The 12-month project will assess the effectiveness of biosolids as an alternative cover material by monitoring its use under varying operational and weather conditions. Should the evaluation provide favorable results, GCIA anticipates seeking longer term approval through a permit modification. Accordingly, GCIA will serve as the project sponsor and applicant for the permit modification to utilize biosolids material as an alternative cover pursuant to Department requirements.

BIOSOLIDS PRODUCT GENERATOR INFORMATION

The GCUA wastewater treatment plant is in the process of upgrading their sludge handling process to produce an air-entrained, dewatered sludge product in the form of a biosolid. The enhanced biosolid is achieved due to conditioning thickened sludge using a proprietary Solid Liquid Gas (SLG) technology. The conditioned sludge will pass through a belt filter press for further dewatering, prior to it being transported for off-site disposal. The SLG technology is a patented process manufactured by Orege North America. The process increases cake dryness with a workable texture sludge reducing polymer usage and odor. The biosolids are air entrained prior to polymer addition and the belt filter press operation. The SLG technology will be installed upstream of one (1) dedicated belt filter press. Currently, this process is being used in Lehigh County, PA, where the sludge generated at the County’s wastewater treatment plant is conditioned with the SLG process and the biosolids produced are land applied to approximately one hundred (100) farms.

BIOSOLIDS PRODUCT STORAGE AND TRANSPORTATION

The air-entrained, dewatered sludge product is a recovered non-hazardous biosolids resource, classified Dry Sewage Sludge (waste type ID 12), per the NJDEP solid waste regulations as. The biosolids product will be stored at the GCUA until it can be beneficially reclaimed at the GCIA.

The enhanced, dewatered biosolids will be conveyed from the discharge end of the belt filter press via a series of belt conveyors to a storage area at the GCUA. The storage area contains dedicated storage for holding and loading the biosolids.

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\GCIA RD&D Application.docx | Page | 2 Under an existing contract between the sister agencies, GCUA will manage the transportation of the biosolids product to the GCIA. Truck routes will be consistent to those currently utilized by the GCUA when hauling incinerator ash to the GCIA. These are the same routes used in conveying GCIA leachate to the GCUA. Significant adverse impact to road traffic is not anticipated during the course of this RD&D.

ENVIRONMENTAL, ENGINEERING CONSULTING AND SUPPORT SERVICES

Environmental, engineering consulting and support services for this RD&D will be provided on behalf of the GCUA and the GCIA by Remington & Vernick Engineers (RVE). RVE has prepared the RD&D Application, proposed assessment, evaluation and reporting documents. RVE will provide oversight as necessary through the course of the RD&D to ensure that the terms of a RD&D approval issued by the NJDEP are implemented and that the RD&D findings are reported accurately. RVE shall serve the project as a team member along with the GCIA, GCUA, and NJDEP.

CONTACT INFORMATION

GCIA Project Sponsor contact information is as follows:

Thomas Sullivan, Administrator Gloucester County Improvement Authority 503 Monroeville Road Swedesboro, NJ 08085 Phone: 856-478-6045 Fax: 856-478-4858 Email: [email protected]

Kimberly Faustino, Assistant Administrator Gloucester County Improvement Authority 503 Monroeville Road Swedesboro, NJ 08085 Phone: 856-478-6045 Fax: 856-478-4858 Email: [email protected]

GCUA Generating Facility contact information is as follows:

Dave Hilbmann, Manager of Operations Gloucester County Utilities Authority 2 Paradise Road West Deptford, NJ 08066 Phone: 856-423-3500, ext. 104 Fax: 856-423-5563 Email: [email protected]

Dennis K. Yoder, P.E. Remington & Vernick Engineers 232 Kings Highway East Haddonfield, NJ 08033 Phone: 856-795-9595, Ext. 1062 Fax: 856-429-5904 Email: [email protected]

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BACKGROUND

Although sludge derived biosolids products have been successfully used in New Jersey and other states as landfill cover material, a complete demonstration of how the GCUA material will meet NJDEP’s regulatory requirements applicable to cover material has not been completed in a formal assessment report. NJDEP’s regulations and technical guidance manuals allow for appropriately permitted solid waste landfill facilities to seek approval for alternative landfill cover materials. The regulations establish many behavioral, physical and analytical criteria for alternative cover materials and set forth landfill permit modification applications guidelines. For non-traditional landfill cover materials which may not possess soil-like properties, the Department provides that the cover material may be evaluated in accordance with the requirements for RD&D projects (see N.J.A.C. 7:26-2A.8(b)15-19.

The RD&D regulations published at N.J.A.C. 7:26-1.7(f)4 require that a RD&D project shall be included by administrative action within the district solid waste management plan for the county or district within which the project is located on the Statewide Solid Waste Management Plan.

GCIA has filed an application with the NJDEP to amend the Certified District Solid Waste Management Plan for the County of Gloucester in accordance with the NJDEP regulations for solid waste planning (N.J.A.C. 7:26-6.11). The Administrative Action Application allows the receipt by the GCIA at its permitted landfill in South Harrison Township of biosolids sludge derived product (waste Type 12) generated by the GCUA at its POTW in West Deptford Township, New Jersey for the purpose of testing for use as alternative landfill cover material in accordance with terms of any approval that may be issued by the NJDEP pursuant to the Department’s landfill and/or RD&D regulations.

OBJECTIVES

The SLG technology is currently used to treat sludge from a wastewater treatment facility in Lehigh County, PA to generate biosolids that are then applied as alternative daily cover at the County Landfill. GCIA believes that the technology can be successfully applied to the sludge generated at GCUA and the biosolids sludge derived product can be used as a blend with other authorized alternative cover materials at the GCIA landfill. The RD&D project aims to successfully demonstrate the compliance of the GCUA biosolids with sanitary landfill daily cover performance requirements as outlined in New Jersey’s landfill regulations. These regulations require that a landfill cover:

• Adequately cover the waste fill; • Impede the entry of rodents and vectors into the waste fill; • Control malodorous emissions from the waste fill; • Provide a fire break; • Resist water erosion; • Resist wind erosion; and • Reduce the occurrence of windblown litter

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\GCIA RD&D Application.docx | Page | 5 Visual inspection of the air entrained biosolids generated from the SLG process do not exhibit any limiting factors that might prevent its use as alternative daily cover. GCIA believes that the alternative cover material will allow the percolation of rain and snow melt to readily pass through the landfill profile and reach the leachate collection system with little to no potential for leachate outcrops to form at the landfill surface. GCIA does not anticipate any pressure buildup due to accumulation of landfill gases under the biosolids. Generally, the biosolids will exhibit all characteristics that are typical of soil that is used as daily cover.

BIOSOLIDS PRODUCT PHYSICAL AND ANALYTICAL PROPERTIES

The biosolids product is an enhanced dewatered sludge produced by conditioning the GCUA sludge with the SLG technology at GCUA’s sewage treatment facility in West Deptford Township. The material is a non-hazardous material in accordance with NJDEP 2015 Residential Standards classification requirements. The moisture content can vary, but is typically between 70 to 80 percent by weight. The material has a mild musty soil like odor.

SCOPE

GCIA proposes that the RD&D be authorized for a period of one (1) year between November 2017 through October 2018. This will provide for a thorough assessment of the biosolids material as a blend with other materials to meet the requirements of daily cover material in accordance with the procedures outlined herein. GCIA proposes to accept less than 100 tons per day of the biosolids sludge derived product to be tested for use as alternative landfill cover material. Daily delivery volume and tonnage will be monitored and adjusted by GCIA as needed based on availability and delivery of authorized alternative cover material for blending with the biosolids. The product will be delivered to the GCIA landfill on a 5 or 6 day per week basis, on an active portion of the landfill in close proximity to the working face. GCIA does not envision a need for stockpiles. Material will be delivered only during operational hours in accordance with GCIA’s landfill permit. The biosolids sludge derived landfill cover product can be applied with traditional landfill operational equipment as blended material mixed with soil or other authorized alternative cover material such as ID 27 contaminated soil or Automobile Shredder Residue (“ASR”) or Recycled Glass Aggregate (“RGA”). The material can be spread with a bulldozer, landfill compactor or equivalent earth handling equipment. The material will be applied and compacted to a minimum thickness of six (6) inches as a mixture that is blended or interspersed with soil or other authorized alternative cover material. The respective cover materials will be pushed through and over each other, in the prescribed ratios, by a bulldozer, landfill compactor or other equivalent equipment such that a mixture of or a patch work of different materials will be evident in the applied cover. The amount of biosolids material to be applied in alternative cover blends will be limited to a maximum of 50% biosolids which is one (1) part by volume of biosolids to one (1) part soil or alternative cover material. This RD&D application includes evaluation of the biosolids as a daily cover material blended with soil or other approved alternative cover material (ID 27 contaminated soil; Automobile Shredder Residue (ASR); or Recycled Glass Aggregate (RGA)).

• Staging and material management procedures to assure

o Placement of the product near the active working face of the landfill on lined areas of the site with provisions for the collection of landfill leachate

o Staging and material management precautions to contain stormwater runoff to direct potentially contaminated liquid to the leachate management system of the landfill

• Spreading, application and blending methods; • Equipment utilization; and • Observation evaluation, testing requirements and reporting protocols.

RD&D DEMONSTRATION REQUIREMENTS

The required criteria and requirements that need to be met for the RD&D testing are summarized below. For ease of reference, the criteria are typed in bold. The material properties that GCIA believes provides the requisite control and the evaluation technique proposed to assess the property follows in Italics.

1) Alternative Landfill Cover Requirements [N.J.A.C. 7:26-2A.8(b)15]

In accordance with NJDEP landfill regulations N.J.A.C. 7:26-2A.8(b)7, all exposed surfaces of solid waste shall be covered at the close of each operating day with a daily cover consisting of six inches of compacted clean soil or alternative cover material subject to the approval of the Department. Any alternative cover material must meet the guidance as set forth in the Department’s “Technical Manual for Cover Material Requests” and meet the following criteria as outlined in N.J.A.C 7:26-2A.8(b)15: i) 7:26-2A.8(b)15.i – The alternative material must impede the entry of rodents and vectors into the waste fill;

Response: The biosolids landfill cover product applied as a blended material mixed with soil or other authorized alternative cover material will provide a barrier to impede the entry of rodents and vectors into the compacted waste material.

Assessment of Performance: Observations will be conducted by visual observation and will be documented as needed by photographs of the application of the product and/or blended material. Observations for rodent activity or visible burrows will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager: and semi-monthly by RVE. Notation of observations will be recorded on the cover material inspection form (see Appendix III) by the landfill manager and RVE during

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\GCIA RD&D Application.docx | Page | 7 observations. If landfill personnel identify any evidence of rodent activity or habitat, same will be made known to the landfill manager and RVE.

ii) 7:26-2A.8(b)15.ii – The alternative material must control malodorous emissions;

Response: The minimum thickness of the biosolids and blended material to be used as alternative daily cover will be at least six (6) inches so as to assist in the mitigation of excessive release of solid waste odors. The biosolids developed through the SLG solution technology treatment process will be aerated, thereby reducing typical sewage sludge odors. The biosolids emit a slight musty soil like odor.

Assessment of Performance: Observations will be conducted by sense of smell and will be recorded on the Cover Material Inspection Form (See Appendix III) by the landfill manager and RVE during observations. Odor observations will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager: and semi-monthly by RVE. If landfill personnel identify any offensive odor emission, it will be brought to the attention of the landfill manager and RVE.

iii) 7:26-2A.8(b)15.iii – The alternative material must provide a firebreak;

Response: The occurrences of fires at well managed landfills are rare. The disposal and compaction of waste material in controlled lift thicknesses that are covered to provide a structural separation of waste materials coupled with the implementation of engineered landfill gas controls has virtually eliminated landfill fire potential. The biosolids alternative cover blend material will provide a structural separation to compacted waste layers or lifts thus providing a physical fire break. The delivered biosolids product has a moisture content of approximately 70 to 80 percent that will aid in the prevention of fires and migration of fire should one occur. This moisture content in conjunction with proper solid waste lift construction and proper management of landfill gases will provide protection against the occurrence of landfill fires.

Assessment of Performance: Observations will be conducted visually and by sense of smell for any evidence of excessive temperature, smoke, or fire. Observations will be recorded on the Cover Material Inspection Form (See Appendix III). Observations will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE.

iv) 7:26-2A.8(b)15.iv – The alternative material must resist erosion;

Response: The biosolids material has similar physical properties to soil and many traditionally accepted alternative landfill cover materials. The fibrous nature of the product and polymers added as part of the treatment process add binding properties to resist the effects of water erosion.

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\GCIA RD&D Application.docx | Page | 8 Assessment of Performance: Observations will be conducted and documented as needed by photographs of alternative cover material following exposure to significant rain events. Observations for visible erosion will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi- monthly by RVE. Notations of observations will be recorded on the Cover Material Inspection Form (See Appendix III) by the landfill manager and RVE. Additional observation frequency will be as needed following rain events or if landfill personnel identify any increased evidence of stormwater erosion. v) 7:26-2A.8(b)15.iv – The alternative material must not be easily windblown;

Response: The biosolids have a moisture content of approximately 70 to 80 percent which aids in the prevention of dust attributable to biosolids covered areas. Although dust caused by windblown fine particles of soil and alternative cover material can occur during extremely dry and high wind conditions even at well managed sanitary landfill facilities, it is expected that the moisture content of the subject biosolids will minimize this condition.

Assessment of Performance: Observations will be conducted for dust and will be documented as needed by photographs (if possible) of dust emanating from biosolids covered areas. The schedule of observations for dust will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE. Notations of observations will be recorded on the Cover Material Inspection Form (See Appendix III). If landfill personnel identify any dust presence relating to the biosolids, it will be brought to the attention of the landfill manager and RVE. vi) 7:26-2A.8(b)15.v – The alternative material must control windblown litter;

Response: Windblown litter is a common occurrence at sanitary landfills; routine litter cleanup must always be conducted. The biosolids material has similar physical properties to soil and many traditionally accepted alternative landfill cover materials and should provide an effective control measure to mitigate the occurrence of windblown waste material similar to that provided by traditional daily cover material.

Assessment of Performance: Observations will be conducted for increased evidence of windblown litter and will be documented as needed by photographs when there is a determination that the litter emanated from areas subject to biosolids cover under the RD&D pilot testing program. The initial schedule of observations for litter will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE. Notations of observations will be recorded on the Cover Material Inspection Form (See Appendix III). If landfill personnel identify any increased evidence of litter attributable to biosolids covered areas, the landfill manager and RVE will be notified.

For purposes of assuring material manageability, preventing contaminated surface water runoff, allowing the controlled venting of landfill gases and, reducing the occurrence of fires, NJDEP has published regulatory criteria for the percent of combustible and material grain size distribution. We note that several of the purposes mirror the requirements of those set forth at N.J.A.C. 7:26- 2A.8(b)15 and can be evaluated in the manner detailed in the proposed performance assessments in section 1 above. The required criteria are summarized below with the regulatory reference pursuant to N.J.A.C. followed by the material properties we believe provide the requisite control and the evaluation technique proposed to assess the property.

i) 7:26-2A.8(b)16.i – The volatile solids or combustible content of the cover shall not exceed 12 percent by weight;

Response: Historically GCUA blended solids have been tested for total solids and volatile solids on a daily basis. This material averages 4.5% total solids with volatile solids comprising 78-82%. It is anticipated that the SLG air-entrained biosolids used as daily cover will be dewatered to 20-30% total solids by weight, while the remaining 70 to 80% of the product will be liquid. The dewater biosolids will be used in a 1:1 blend by volume with other approved daily cover. Accounting for the blend, the percent by weight of volatile solids is not expected to exceed 12%.

Assessment of Performance: GCUA will conduct daily analytical for total solids and volatile solids of the biosolids product at their in-house laboratory facility throughout the course of the RD&D. Also, GCUA will conduct an analytical of total solids and volatile solids of the GCIA daily cover material prior to blending with the biosolid, along with a measurement of SLG air-entrained biosolids density to convert from volume to weight for calculations. The results and calculations will be provided as part of a final report submitted at the conclusion of the RD&D. ii) 7:26-2A.8(b)16.ii – No more than 20 percent of fine grained materials shall pass No. 200 sieve;

Response: Use of biosolids as an individual daily cover material or in combination with soil or other authorized alternative cover material as a daily cover material will meet the underlying intent of this particle size standard.

• To prevent the formation of impervious vertical barriers to the downward flow of leachate that may lead to leachate outcrops and potential offsite discharge of leachate as stormwater. • To prevent vertical barriers to the upward flow of landfill gas that may lead to lateral migration of potentially explosive or flammable gases from the landfill property. • To provide filtration or adsorption of potentially odorous gases that vent to the landfill surface to reduce off-site odor impacts. • To reduce wind and water erosion of fine grained particles of cover material that can contribute to dust emissions in air and sediment transport to surface water.

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\GCIA RD&D Application.docx | Page | 10 Accordingly, the final condition of the biosolids cover will allow leachate to easily percolate through the landfill profile and reach the leachate collection system with little to no potential for leachate outcrops to form at the landfill surface. Likewise, landfill gases will permeate the biosolids at a rate that will prevent undue pressure build up. The structure and moisture retention properties of the biosolids will promote the adsorption of odorous compounds that may be entrained in the landfill gas.

Assessment of Performance: The GCUA, in cooperation with the GCIA, have completed particle size distribution analyses on a variety of biosolids materials with results presented in the Analytical Report dated 11/25/15, Appendix IV. The analyses evaluated the impact of digestion, dewatering, and drying on the grain size distribution of a biosolid. The results showed the biosolids met the gradation restrictions of > 40% passing a #10 sieve and < 20% passing a #200 sieve, regardless of processing techniques.

During the RD&D, a particle size distribution analysis will be conducted on the biosolids material for use as daily cover once a month.

iii) 7:26-2A.8(b)16.iii - At least 40 percent by weight of the fragments in the soil admixture shall be capable of passing through a No. 10 mesh sieve;

Response: The underlying intent of this criteria is to avoid the use of extremely coarse grained materials such as gravel and stone so as to reduce the volume of voids. Coarse grained materials when used as daily cover can lead to offsite migration of landfill gases as the gas can readily escape through the voids into the atmosphere.

During the RD&D, a particle size distribution analysis will be conducted on the biosolids material for use as daily cover once a month. iv) 7:26-2A.8(b)16.iv - Particle sizes shall not exceed six (6) inches in diameter;

Response: Particles are limited in size to six (6) inches, which is consistent with the minimum depth of cover. Soils up to six (6) inches are classified as silts, sands, and small gravels. Combinations of these classifications will work on-site to provide structure and integrity to the layer of daily cover.

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\GCIA RD&D Application.docx | Page | 11 Assessment of Performance: The presence of large particles within the biosolids product can be determined from visual observation of delivered material as well as during the biosolids loading procedure at GCUA.

Biosolids when spread is not anticipated to result in particle sizes approaching six (6) inches. The presence or absence of large particles can be determined through the visual observations that will be routinely conducted. Observations will be recorded on the Cover Material Inspection Form (See Appendix III). Observations will be made: daily by experienced landfill and treatment plant personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE.

3) Soil-like Material Laboratory Testing Requirements [N.J.A.C. 7:26- 2A.8(b)17]

For alternative cover materials that possess soil-like properties, the Department’s regulations specify additional laboratory testing depending on the nature of the material and its intended use as daily, intermediate of final cover material. The required criteria are summarized below with the regulatory reference pursuant to N.J.A.C. (In Bold) followed by the evaluation technique proposed to assess the property (provided in Italics): i) 7:26-2A.8(b)17.i – The following tests are required for the proposed alternative daily cover:

• Solids Content; • Percent volatile solids; • Grain size analysis; and, • Moisture content

Response: The above-mentioned parameters are consistent with items under 7:26-2A.8(b)16 i through iv, previously addressed. The parameters will be measured by the GCUA in-house laboratory facility (solids content, percent volatile solids, and moisture content) and by a geotechnical consultant laboratory, (for grain size analysis). One (1) sample will be collected every week for in-house analysis. Grain size analysis will be performed once a month.

RD&D ANALYTICAL DATA LIMITATIONS

Traditional laboratory testing procedures do not always reflect the behavior and properties of the biosolids with respect to the purposes for which the above criteria were adopted by the Department. For instance, percent volatile solids are derived from a laboratory procedure that drives off all retained moisture and subjects the material to sustained temperatures of 550 degrees centigrade. Such a test method is not reflective of field scale conditions. It is the intent of this RD&D to consider analytical data in conjunction with full scale operations.

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The biosolids sludge derived product will be delivered by truck daily. The material will be unloaded near the active face of the landfill to facilitate application with a bulldozer or landfill compactor at the end of the day. All working areas of the landfill are underlain by an approved leachate collection system that will collect any liquid. The biosolids cover material will be utilized as cover at the end of the operating day. GCIA anticipates using the biosolids sludge derived product on a daily basis and will adjust daily deliveries to meet daily cover demands. The daily application of the biosolids, to be tested for use as an alternative daily cover, as part of the RD&D program will not exceed 100 tons/day.

BIOSOLIDS PRODUCT ACCEPTANCE/STORAGE

The product will be delivered by truck to the GCIA landfill on a 5 or 6 day per week basis and will be staged on an active portion of the landfill in close proximity to the working face (See Appendix V - Process Flow Diagram). GCIA does not envision a need for stockpiles.

DAILY COVER PLACEMENT

The material will be spread by use of a bulldozer or landfill compactor at the end of the day. All working areas of the landfill are underlain by an approved leachate collection system that will collect any liquid resulting. The biosolids cover material will be utilized as cover at the end of the operating day. GCIA proposes to place the biosolids sludge derived product as follows:

• As a daily cover material blended with o Soil cover o Approved alternative cover material o ID 27 contaminated soil o Automobile Shredder Residue (ASR) o Recycled Glass Aggregate (RGA)

The biosolids blended cover material will be placed and compacted to a minimum thickness of six (6) inches for use as daily cover. GCIA will apply the biosolids as a mixture with other authorized alternative cover material. The biosolids will be placed at the active working face of the landfill in close proximity to a sufficient volume of other cover materials to achieve a blend of not more than 1 part by volume of biosolids to 1 part other authorized alternative cover material. The respective cover materials will be pushed through and over each other by a bulldozer, landfill compactor or other equivalent equipment such that a mixture of or a patchwork of different materials will be evident in the applied daily cover (See Appendix V - Process Flow Diagram).

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As discussed in previous sections of this application, observations of the performance of the biosolids and various blends of alternative cover material will be conducted and recorded by experienced landfill (GCIA) and wastewater treatment (GCUA) personnel, and Remington & Vernick Engineers (RVE). The GCIA landfill manager and staff are experienced in all aspects of landfill operations and maintenance. Observations with regard to adequacy of cover, presence of erosion, dust, ponding of water, odor, litter and fire are conducted on a continuous basis and, accordingly, distinctions or changes attributable to the use of biosolids blended cover material will be readily apparent and can be documented by the GCIA. GCIA maintains detailed records with respect to volumes and tonnage of all materials received at its landfill including alternative cover material. Volume and tonnage of biosolids used during the RD&D will be summarized from these records. In addition, GCIA maintains a weather station that can provide temperature wind and rainfall information.

RECORDKEEPING

A RD&D Cover Material Evaluation Form has been developed to record observations with regard to:

• Material properties and behavior • Type of alternative cover used for blending • Visual observations • Odor observations • Equipment/vehicle mobility • Difficulties encountered/recommendations • Photographs

The RD&D Cover Material Inspection Form is included in this application as Appendix III. The form may be adjusted or refined to provide additional assessment methods or to reduce recordkeeping burdens as the RD&D proceeds. In general, observations will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE.

LABORATORY TESTING

Laboratory testing will be performed for the parameters listed above in sections 7:26-2A.8(b)16i though iv and 7:26-2A.8(b) 17i. The parameters will be measured by the GCUA in-house laboratory facility (solids content, percent volatile solids, and moisture content) and by a geotechnical consultant laboratory (for grain size analyses).

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RVE will provide a summary report that will include recommendations, material receipt, alternative cover usage, and observations as part of the RD&D. The report will be submitted within sixty (60) days of the termination of the RD&D to the Department. A proposed outline of the report is provided below:

Overview

Material receipt and handling

Summary of the methods of use and application • Listing of alternative cover materials blended • Application thicknesses

Summary of cover material performance • Adequacy of covering waste fill; • Impedance of entry of rodents and vectors into the waste fill; • Malodorous emission control; • Fire prevention; • Water erosion; • Wind erosion; • Windblown Litter control; and • Ability to provide permeability of stormwater and gas

Conclusions and Recommendations

Appendices • Copies of field evaluation forms • Photo log • Laboratory Results

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APPENDIX I – SITE PLAN

APPENDIX II – CORRESPONDENCE

APPENDIX III – COVER MATERIAL INSPECTION FORM

GLOUCESTER COUNTY IMPROVEMENT AUTHORITY

Date: Time: Weather: Daily Cover Material Inspection Form

1) Biosolid Blended with: ASR Soil RGA Other 2) Blend Ratio: Biosolid/Alternate Cover +/- 1:1 Yes No 3) Application Thickness > Six (6) and < Twelve (12) Inches Yes No 4) Adequate Coverage Provided: Yes No 5) Rodents or Vectors Adequately Controlled: Yes No 6) Odor Control Adequate: Yes No 7) Landfill Gas Permeability Adequate: Yes No 8) Fire Control Adequate: Yes No 9) Water Erosion Adequately Controlled: Yes No 10) Storm Water Infiltrates Cover: Yes No 11) Wind Erosion/Dust Adequately Controlled: Yes No 12) Litter Adequately Controlled: Yes No 13) Maximum Particle Size < 6 inches: Yes No 14) Equipment and Vehicles Maneuver Adequately: Yes No

Difficulties Encountered/Recommendations: [Separate Page(s) Attached:] Yes No

Photos: Yes No Completed By: (Print) Title: Signature:

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\Appendix\Appendix III - Evaluation Form Rev

APPENDIX IV – PARTICLE SIZE DISTRIBUTION RESULTS

Particle Size Distribution Report 6 in. 3 in. 2 in. in.1½ 1 in. ¾ in. ½ in. in. 3/8 #4 #10 #20 #30 #40 #60 #100 #140 #200 100

40 PERCENT FINER PERCENT

0 100 10 1 0.1 0.01 0.001 GRAIN SIZE - mm. % Gravel % Sand % Fines % +3" Coarse Fine Coarse Medium Fine Silt Clay 0.0 0.0 0.0 38.4 52.5 5.1 4.0

LL PL D85 D60 D50 D30 D15 D10 Cc Cu 3.4002 1.9257 1.5202 0.9060 0.5553 0.4462 0.96 4.32

MATERIAL DESCRIPTION TEST DATE USCS NM DARK BROWN TO BLACK UNDIGESTED SEWAGE SLUDGE 11/25/15

Project No. 244285Client: REMINGTON & VERNICK ENGINEERS, INC. Remarks: Project: GCUA DIGESTOR PROJECT AS REQUESTED BY CLIENT, SAMPLE WAS ONLY DRY Source: UNDIGESTED (DEWATERED) DRIED Sample No.: CRUSHED SIEVED *SEE SUMMARY TABLE FOR ADDITIONAL NOTES TRC Engineers, Inc.

Mt. Laurel, NJ Figure 2

Tested By: TBT 11/25/15 Checked By: PWK 11/25/15

APPENDIX V – PROCESS FLOW DIAGRAM

Gloucester County Improvement Authority RD&D Process Flow Diagram for Management of Biosolids Alternate Cover

Applied as Daily Cover Observation and Monitoring ‐ Applied in minimum 6 inch lift using available ‐ Record Notes on application and performance. landfill equipment (See RD&D Alternative Cover Evaluation Form) ‐ Mixed to not exceed 50% Biosolids with Other ‐ Observation to be made daily Approved Cover* ‐ Photos taken during and following application ‐ Area buried with Refuse within or covered within 1 day

Delivery to Working Face Reporting ‐ Piles for daily use located very close to working ‐ Provide copies of the daily face recordkeeping logs and any ‐ Several small piles may be placed at various photos of the project area to locations RVE weekly. Delivery ‐ Alternate cover to be used for blending will be ‐ Truck weighed in staged in close proximity to Biosolids to ‐ Tonnage recorded facilitate blending ‐ Volume estimated based on vehicle capacity

*NOTE: Other Approved Cover 1. Soil/ID 27 Soil 2. Auto Shredder Residue (ASR) GCIA RD&D Process Flow Diagram for Management of Bisolids 3. Recycled Glass Aggregate (RGA) 9/19/2016 Alternate Cover

APPENDIX VI – GCIA AUTHORIZATION LETTER

Attachment B

RD&D Application (Modification) – September 2018 DEP Approval – January 2020

GLOUCESTER COUNTY IMPROVEMENT AUTHORITY

GLOUCESTER COUNTY LANDFILL

Modification of Research Development & Demonstration (RD&D) Application

September 2018 (Revised) October 2017 (Previous Submission)

Prepared for Gloucester County Improvement Authority, West Deptford, NJ

Prepared By

232 Kings Highway East, Haddonfield, NJ 08033 TABLE OF CONTENTS

INTRODUCTION ...... 1

BACKGROUND AND PROJECT INFORMATION ...... 3 Project Sponsor ...... 3 Biosolids Product Generator Information ...... 3 Biosolids Product Storage and Transportation ...... 4 Environmental, Engineering Consulting and Support Services ...... 4 Contact Information ...... 4

RD&D OVERVIEW AND OBJECTIVES ...... 6 Background ...... 6 Objectives ...... 6 Biosolids Product Physical and Analytical Properties ...... 7 Scope ...... 7 RD&D Demonstration Requirements ...... 8 1) Alternative Landfill Cover Requirements [N.J.A.C. 7:26-2A.8(b)15] ...... 8 2) Alternative Cover Performance Requirements [N.J.A.C. 7:26-2A.8(b)16] ...... 11 Soil-like Material Laboratory Testing Requirements [N.J.A.C. 7:26- ...... 13 3) 2A.8(b)17] ...... 13 RD&D Analytical Data Limitations ...... 13

RD&D IMPLEMENTATION AND MANAGEMENT ...... 15 Biosolids Product Acceptance/Storage ...... 15 Daily Cover Placement...... 15

RECORDKEEPING AND REPORTING ...... 16 Recordkeeping ...... 16 Laboratory Testing ...... 16 Reporting ...... 17

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\Residuals\RDD - Revised 083018\GCIA RD&D Application.docx i APPENDICES

APPENDIX I – Site Plan

APPENDIX II – Cover Material Inspection Form

APPENDIX III – Particle Size Distribution Results

APPENDIX IV – RD&D Application (October 2017)

APPENDIX V – RD&D Application Approval (April 2018)

APPENDIX VI – Process Flow Diagram

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\Residuals\RDD - Revised 083018\GCIA RD&D Application.docx ii INTRODUCTION

GCUA is seeking a modification to a Research Development and Demonstration (RD&D) application (Appendix IV), approved by the Department on April 11, 2018 (Appendix V). The current approval allows GCIA to evaluate the effectiveness of using an air entrained biosolid, enhanced through the Orege process, as part of a blend with soil or other authorized alternative cover materials for use as a daily cover material. The biosolid is generated at the Gloucester County Utilities Authority (GCUA), a sister agency, as part of sludge handling during the wastewater treatment process and is being evaluated for use as alternative daily cover over a twelve-month (12) period by monitoring its use under varying operational and weather conditions. GCIA proposes to modify the RD&D application to include and evaluate two (2) additional biosolids for use as part of a blend with soil or other authorized alternative cover materials for use as a daily cover material. The additional biosolids proposed to be evaluated include i) digested sludge, which is enhanced by the Orege process (air entrained) prior to dewatering, and ii) digested dewatered sludge. Existing and proposed plant process diagrams, identifying the three (3) biosolids streams are included as Appendix VI.

Should the RD&D provide favorable results, GCIA anticipates seeking longer term approval through a permit modification.

In accordance with the Department’s Division of Solid & Hazardous Waste Regulations and Technical Manuals, the use of an alternative material for daily landfill cover must be approved as

T:\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\Residuals\RDD - Revised 082718\Application\Report\GCIA RD&D Application.docx | P a g e | 1 a modification to a Sanitary Landfill Facility permit. Since biosolids is not a soil and is a non- traditional cover material, the Department provides that its use may be evaluated in accordance with the requirements for RD&D projects outlined in N.J.A.C. 7:26-2A.8(b)19.

Copies of the previous RD&D application, and Department approval is being submitted with this application as a reference.

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PROJECT SPONSOR

GCIA is seeking a modification to an approved RD&D application, to include two (2) additional biosolids processes (in addition to the one (1) approved) and evaluate their effectiveness as part of a blend with soil or other authorized alternative cover materials for use as a daily cover material. The 12-month project will assess the effectiveness of biosolids generated by three (3) treatment processes as an alternative cover material by monitoring their use under varying operational and weather conditions. Should the evaluation provide favorable results, GCIA anticipates seeking longer term approval through a permit modification. Accordingly, GCIA will serve as the project sponsor and applicant for the permit modification to utilize biosolids material as an alternative cover pursuant to Department requirements.

BIOSOLIDS PRODUCT GENERATOR INFORMATION

Concurrently, GCUA is in the process of upgrading its wastewater treatment process. Two (2) new anaerobic digesters are being built and will be operational later this year. As a result of unit process improvements, RVE would like to modify the existing RD&D application to include and evaluate two (2) additional biosolids for use as part of a blend with soil or other authorized alternative cover materials for use as a daily cover material. The additional biosolids proposed to be evaluated include i) digested sludge, which is enhanced by the SLG process prior to dewatering, and ii) digested dewatered sludge. An existing plant process diagram and a proposed plant process diagram, identifying the three (3) biosolids streams is included as Appendix VI.

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The dewatered sludge products are a recovered non-hazardous biosolids resource, classified Dry Sewage Sludge (waste type ID 12), per the NJDEP solid waste regulations as. The biosolid products will be stored at the GCUA until they can be beneficially reclaimed at the GCIA.

The dewatered biosolids will be conveyed from the discharge end of the belt filter press via a series of belt conveyors to a storage area at the GCUA. The storage area contains dedicated storage for holding and loading the biosolids. The three (3) proposed biosolid materials to be evaluated will be stored separate from each other and will not be mixed.

Under an existing contract between the sister agencies, GCUA will manage the transportation of the biosolid products to the GCIA. Truck routes will be consistent to those currently utilized by the GCUA when hauling incinerator ash to the GCIA. These are the same routes used in conveying GCIA leachate to the GCUA. Significant adverse impact to road traffic is not anticipated during the course of this RD&D.

ENVIRONMENTAL, ENGINEERING CONSULTING AND SUPPORT SERVICES

CONTACT INFORMATION

GCIA Project Sponsor contact information is as follows:

Thomas Sullivan, Administrator Gloucester County Improvement Authority 503 Monroeville Road Swedesboro, NJ 08085 Phone: 856-478-6045 Fax: 856-478-4858 Email: [email protected]

Kimberly Faustino, Assistant Administrator Gloucester County Improvement Authority 503 Monroeville Road Swedesboro, NJ 08085 Phone: 856-478-6045 Fax: 856-478-4858 Email: [email protected]

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Dave Hilbmann, Manager of Operations Gloucester County Utilities Authority 2 Paradise Road West Deptford, NJ 08066 Phone: 856-423-3500, ext. 104 Fax: 856-423-5563 Email: [email protected]

Remington & Vernick Engineers contact information is as follows:

Dennis K. Yoder, P.E. Remington & Vernick Engineers 232 Kings Highway East Haddonfield, NJ 08033 Phone: 856-795-9595, Ext. 1062 Fax: 856-429-5904 Email: [email protected]

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BACKGROUND

Although sludge derived biosolid products have been successfully used in New Jersey and other states as landfill cover material, a complete demonstration of how the GCUA material will meet NJDEP’s regulatory requirements applicable to cover material has not been completed in a formal assessment report. NJDEP’s regulations and technical guidance manuals allow for appropriately permitted solid waste landfill facilities to seek approval for alternative landfill cover materials. The regulations establish many behavioral, physical and analytical criteria for alternative cover materials and set forth landfill permit modification applications guidelines. For non-traditional landfill cover materials which may not possess soil-like properties, the Department provides that the cover material may be evaluated in accordance with the requirements for RD&D projects (see N.J.A.C. 7:26-2A.8(b)15-19.

OBJECTIVES

The objective of the RD&D application is to evaluate the effectiveness of utilizing digested and dewatered sludge as an alternative daily cover when used in combination with other approved daily cover materials at GCIA. Additionally, two (2) other biosolids materials generated at GCUA and enhanced by using a proprietary Solid Liquid Gas (SLG) process manufactured by Orege North America, are proposed to be evaluated as part of the project.

• Adequately cover the waste fill;

T:\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\Residuals\RDD - Revised 082718\Application\Report\GCIA RD&D Application.docx | P a g e | 6 • Impede the entry of rodents and vectors into the waste fill; • Control malodorous emissions from the waste fill; • Provide a fire break; • Resist water erosion; • Resist wind erosion; and • Reduce the occurrence of windblown litter.

Visual inspection of the air entrained biosolids generated from the SLG process do not exhibit any limiting factors that might prevent its use as alternative daily cover. GCIA believes that the alternative cover material will allow the percolation of rain and snow melt to readily pass through the landfill profile and reach the leachate collection system with little to no potential for leachate outcrops to form at the landfill surface. GCIA does not anticipate any pressure buildup due to accumulation of landfill gases under the biosolids. Generally, the biosolids will exhibit all characteristics that are typical of soil that is used as daily cover.

BIOSOLIDS PRODUCT PHYSICAL AND ANALYTICAL PROPERTIES

The biosolids product is dewatered sludge produced as part of the wastewater treatment process and may be conditioned with the SLG technology at GCUA’s sewage treatment facility in West Deptford Township. The material is a non-hazardous material in accordance with NJDEP 2015 Residential Standards classification requirements. The moisture content can vary, but is typically between 70 to 80 percent by weight. The material has a mild musty soil like odor.

SCOPE

GCIA proposes that the approved RD&D be modified and authorized for a period of one (1) year between October 2018 through September 2019. This will provide for a thorough assessment of the three (3) biosolids materials as a blend with other materials to meet the requirements of daily cover material in accordance with the procedures outlined herein. GCIA proposes to accept less than 100 tons per day (all three (3) biosolids stream combined) of the biosolids sludge derived products to be tested for use as alternative landfill cover material. Daily delivery volume and tonnage will be monitored and adjusted by GCIA as needed based on availability and delivery of authorized alternative cover material for blending with the biosolids. The product will be delivered to the GCIA landfill on a 5 or 6 day per week basis, on an active portion of the landfill in close proximity to the working face. GCIA does not envision a need for stockpiles. Material will be delivered only during operational hours in accordance with GCIA’s landfill permit. The biosolids sludge derived landfill cover product can be applied with traditional landfill operational equipment as blended material mixed with soil or other authorized alternative cover material such as ID 27 contaminated soil or Automobile Shredder Residue (“ASR”) or Recycled Glass Aggregate (“RGA”). The material can be spread with a bulldozer, landfill compactor or equivalent earth handling equipment. The material will be applied and compacted to a minimum thickness of six (6) inches as a mixture that is blended or interspersed with soil or other authorized alternative cover material. The respective cover materials will be pushed through and over each other, in the prescribed ratios, by a bulldozer, landfill compactor or other equivalent equipment such that a mixture of or a patch work of different materials will be evident in the applied cover. The amount of biosolids material to be applied in alternative cover blends will be limited to a maximum of

T:\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\Residuals\RDD - Revised 082718\Application\Report\GCIA RD&D Application.docx | P a g e | 7 50% biosolids which is one (1) part by volume of biosolids to one (1) part soil or alternative cover material. This RD&D application includes evaluation of the biosolids as a daily cover material blended with soil or other approved alternative cover material (ID 27 contaminated soil; Automobile Shredder Residue (ASR); or Recycled Glass Aggregate (RGA)).

The RD&D Product delivery handling and management requirements as follows:

• Staging and material management procedures to assure

o Placement of the product near the active working face of the landfill on lined areas of the site with provisions for the collection of landfill leachate

o Staging and material management precautions to contain stormwater runoff to direct potentially contaminated liquid to the leachate management system of the landfill

• Spreading, application and blending methods; • Equipment utilization; and • Observation evaluation, testing requirements and reporting protocols.

RD&D DEMONSTRATION REQUIREMENTS

1) Alternative Landfill Cover Requirements [N.J.A.C. 7:26-2A.8(b)15]

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Assessment of Performance: Observations will be conducted by sense of smell and will be recorded on the Cover Material Inspection Form (See Appendix II) by the landfill manager and RVE during observations. Odor observations will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager: and semi-monthly by RVE. If landfill personnel identify any offensive odor emission, it will be brought to the attention of the landfill manager and RVE. iii) 7:26-2A.8(b)15.iii – The alternative material must provide a firebreak;

Assessment of Performance: Observations will be conducted visually and by sense of smell for any evidence of excessive temperature, smoke, or fire. Observations will be recorded on the Cover Material Inspection Form (See Appendix II). Observations will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE.

T:\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\Residuals\RDD - Revised 082718\Application\Report\GCIA RD&D Application.docx | P a g e | 9 iv) 7:26-2A.8(b)15.iv – The alternative material must resist erosion;

Assessment of Performance: Observations will be conducted and documented as needed by photographs of alternative cover material following exposure to significant rain events. Observations for visible erosion will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi- monthly by RVE. Notations of observations will be recorded on the Cover Material Inspection Form (See Appendix II) by the landfill manager and RVE. Additional observation frequency will be as needed following rain events or if landfill personnel identify any increased evidence of stormwater erosion. v) 7:26-2A.8(b)15.iv – The alternative material must not be easily windblown;

Assessment of Performance: Observations will be conducted for dust and will be documented as needed by photographs (if possible) of dust emanating from biosolids covered areas. The schedule of observations for dust will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE. Notations of observations will be recorded on the Cover Material Inspection Form (See Appendix II). If landfill personnel identify any dust presence relating to the biosolids, it will be brought to the attention of the landfill manager and RVE. vi) 7:26-2A.8(b)15.v – The alternative material must control windblown litter;

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2) Alternative Cover Performance Requirements [N.J.A.C. 7:26-2A.8(b)16]

• To prevent the formation of impervious vertical barriers to the downward flow of leachate that may lead to leachate outcrops and potential offsite discharge of leachate as stormwater.

T:\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\Residuals\RDD - Revised 082718\Application\Report\GCIA RD&D Application.docx | P a g e | 11 • To prevent vertical barriers to the upward flow of landfill gas that may lead to lateral migration of potentially explosive or flammable gases from the landfill property. • To provide filtration or adsorption of potentially odorous gases that vent to the landfill surface to reduce off-site odor impacts. • To reduce wind and water erosion of fine grained particles of cover material that can contribute to dust emissions in air and sediment transport to surface water. Accordingly, the final condition of the biosolids cover will allow leachate to easily percolate through the landfill profile and reach the leachate collection system with little to no potential for leachate outcrops to form at the landfill surface. Likewise, landfill gases will permeate the biosolids at a rate that will prevent undue pressure build up. The structure and moisture retention properties of the biosolids will promote the adsorption of odorous compounds that may be entrained in the landfill gas.

Assessment of Performance: The GCUA, in cooperation with the GCIA, have completed particle size distribution analyses on a variety of biosolids materials with results presented in the Analytical Report dated 11/25/15, Appendix III. The analyses evaluated the impact of digestion, dewatering, and drying on the grain size distribution of a biosolid. The results showed the biosolids met the gradation restrictions of > 40% passing a #10 sieve and < 20% passing a #200 sieve, regardless of processing techniques.

During the RD&D, a particle size distribution analysis will be conducted on the biosolids material for use as daily cover once a month. iii) 7:26-2A.8(b)16.iii - At least 40 percent by weight of the fragments in the soil admixture shall be capable of passing through a No. 10 mesh sieve;

Assessment of Performance: The GCUA, in cooperation with the GCIA, have completed particle size distribution analyses on a variety of biosolids materials with results presented in the Analytical Report dated 11/25/15, Appendix III. The analyses evaluated the impact of digestion, dewatering, and drying on the grain size distribution of a biosolid. The results showed the biosolids met the gradation restrictions of > 40% passing a #10 sieve and < 20% passing a #200 sieve, regardless of processing techniques.

During the RD&D, a particle size distribution analysis will be conducted on the biosolids material for use as daily cover once a month.

Assessment of Performance: The presence of large particles within the biosolids product can be determined from visual observation of delivered material as well as during the biosolids loading procedure at GCUA.

Biosolids when spread is not anticipated to result in particle sizes approaching six (6) inches. The presence or absence of large particles can be determined through the visual observations that will be routinely conducted. Observations will be recorded on the Cover Material Inspection Form (See Appendix II). Observations will be made: daily by experienced landfill and treatment plant personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE.

3) Soil-like Material Laboratory Testing Requirements [N.J.A.C. 7:26- 2A.8(b)17]

• Solids Content; • Percent volatile solids; • Grain size analysis; and, • Moisture content

RD&D ANALYTICAL DATA LIMITATIONS

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BIOSOLIDS PRODUCT ACCEPTANCE/STORAGE

The products will be delivered by truck to the GCIA landfill on a 5 or 6 day per week basis and will be staged on an active portion of the landfill in close proximity to the working face (See Appendix VI - Process Flow Diagram). GCIA does not envision a need for stockpiles.

DAILY COVER PLACEMENT

• As a daily cover material blended with o Soil cover o Approved alternative cover material o ID 27 contaminated soil o Automobile Shredder Residue (ASR) o Recycled Glass Aggregate (RGA)

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RECORDKEEPING

A RD&D Cover Material Evaluation Form has been developed to record observations with regard to:

The RD&D Cover Material Inspection Form is included in this application as Appendix II. The form may be adjusted or refined to provide additional assessment methods or to reduce recordkeeping burdens as the RD&D proceeds. In general, observations will be made: daily by experienced landfill personnel; weekly by the GCIA landfill manager; and semi-monthly by RVE.

LABORATORY TESTING

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Overview

Material receipt and handling

Summary of the methods of use and application • Listing of alternative cover materials blended • Application thicknesses

Conclusions and Recommendations

Appendices • Copies of field evaluation forms • Photo log • Laboratory Results

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APPENDIX I – SITE PLAN

APPENDIX II – COVER MATERIAL INSPECTION FORM

GLOUCESTER COUNTY IMPROVEMENT AUTHORITY

Date: Time: Weather: Daily Cover Material Inspection Form

Difficulties Encountered/Recommendations: [Separate Page(s) Attached:] Yes No

Photos: Yes No Completed By: (Print) Title: Signature:

\\rve232\Groups\Facilities\Water\Facilities06on\NJ Gloucester\0800M GCUA\0800M046 Digester\Permits\residuals\RDD\Application\Appendix\Appendix III - Evaluation Form Rev

APPENDIX III – PARTICLE SIZE DISTRIBUTION RESULTS

Particle Size Distribution Report 6 in. 3 in. 2 in. in.1½ 1 in. ¾ in. ½ in. in. 3/8 #4 #10 #20 #30 #40 #60 #100 #140 #200 100

40 PERCENT FINER PERCENT

0 100 10 1 0.1 0.01 0.001 GRAIN SIZE - mm. % Gravel % Sand % Fines % +3" Coarse Fine Coarse Medium Fine Silt Clay 0.0 0.0 0.0 38.4 52.5 5.1 4.0

LL PL D85 D60 D50 D30 D15 D10 Cc Cu 3.4002 1.9257 1.5202 0.9060 0.5553 0.4462 0.96 4.32

MATERIAL DESCRIPTION TEST DATE USCS NM DARK BROWN TO BLACK UNDIGESTED SEWAGE SLUDGE 11/25/15

Mt. Laurel, NJ Figure 2

Tested By: TBT 11/25/15 Checked By: PWK 11/25/15

Particle Size Distribution Report 6 in. 6 in. 3 in. 2 in. 1½ in. 1 in. ¾ in. ½ in. 3/8 #4 #10 #20 #30 #40 #60 #100 #140 #200 100

40 PERCENT FINER PERCENT

0 100 10 1 0.1 0.01 0.001 GRAIN SIZE - mm. % Gravel % Sand % Fines % +3" Coarse Fine Coarse Medium Fine Silt Clay 0.0 0.0 37.3 7.3 22.2 0.6 32.6

LL PL D85 D60 D50 D30 D15 D10 Cc Cu 11.2795DRAFT 3.8065 1.3718 MATERIAL DESCRIPTION TEST DATE USCS NM BLACK SEWAGE SLUDGE* 05/30/18 370.2

Project No. 244285 Client: REMINGTON & VERNICK ENGINEERS, INC. Remarks: Project: GCUA DIGESTOR PROJECT SEE SUMMARY TABLE FOR NOTES Source of Sample: SEWAGE SLUDGE 2018 Sample Number: BULK

TRC Engineers, Inc.

Mt. Laurel, NJ Figure

Tested By: CWZ 05/30/18 Checked By: JPB 06/14/18

Particle Size Distribution Report 6in. 3in. 2in. in.1½ 1in. in.¾ in.½ 3/8in. #4 #10 #20 #30 #40 #60 #100 #140 #200 100 GCUA SPECIFICATION

40 PERCENT FINER PERCENT 30

0 100 10 1 0.1 0.01 0.001 GRAIN SIZE - mm. % Gravel % Sand % Fines % +3" Coarse Fine Coarse Medium Fine Silt Clay 0.0 0.0 44.8 13.9 7.8 15.4 18.1

Test Results (ASTM D 422 & ASTM D 1140) Material Description Opening Percent Spec.* Pass? BLACK SEWAGE SLUDGE* Size Finer (Percent) (X=Fail) 3/4" 100.0 3/8" 87.0 Atterberg Limits (ASTM D 4318) #4 55.2 PL= LL= PI= #10 41.3 40.0 - 100.0 #40 33.5 Classification #200 18.1 0.0 - 20.0 USCS (D 2487)= AASHTO (M 145)= Coefficients D90= 10.4128 D85= 9.0316 D60= 5.3329 D50= 4.0338 D30= 0.2645 D15= D10= Cu= Cc= Remarks *PARTICLE SIZE DISTRIBUTION MAY BE SKEWED DUE TO FIBROUS MATERIAL RETAINED ON SAND & GRAVEL- SIZED SIEVES. Date Received: 06/25/18 Date Tested: 07/19/18 Tested By: CWZ 07/19/18 Checked By: J.BENJAMIN Title: SR GEOTECH ENGINEER * GCUA SPECIFICATION Source of Sample: SEWAGE SLUDGE 2018 Date Sampled: 06/19/18-06/ Sample Number: BULK (JUNE SAMPLE) TRC Client: REMINGTON & VERNICK ENGINEERS, INC. Engineers, Inc. Project: GCUA DIGESTOR PROJECT Mt. Laurel, NJ Project No: 244285 Figure 2 Particle Size Distribution Report 6in. 3in. 2in. in.1½ 1in. in.¾ in.½ 3/8in. #4 #10 #20 #30 #40 #60 #100 #140 #200 100 GCUA SPECIFICATION

40 PERCENT FINER PERCENT 30

0 100 10 1 0.1 0.01 0.001 GRAIN SIZE - mm. % Gravel % Sand % Fines % +3" Coarse Fine Coarse Medium Fine Silt Clay 0.0 0.0 54.1 2.0 21.0 5.3 17.6

TEST RESULTS (ASTM D 422) Material Description Opening Percent Spec.* Pass? BLACK SEWAGE SLUDGE* Size Finer (Percent) (X=Fail) 3/4" 100.0 3/8" 91.0 Atterberg Limits (ASTM D 4318) #4 45.9 PL= LL= PI= #10 43.9 40.0 - 100.0 #40 22.9 Classification #200 17.6 0.0 - 20.0 USCS (D 2487)= AASHTO (M 145)= Coefficients D90= 9.3384 D85= 8.5576 D60= 6.0238 D50= 5.1529 D30= 0.8259 D15= D10= Cu= Cc= Remarks *PARTICLE SIZE DISTRIBUTION MAY BE SKEWED DUE TO FIBROUS MATERIAL RETAINED ON SAND & GRAVEL- SIZED SIEVES. Date Received: 07/25/18 Date Tested: 08/10/18 Tested By: C. ZIELKE Checked By: P. KAZANIWSKY Title: CHIEF GEOTECH ENGINEER * GCUA SPECIFICATION Source of Sample: SEWAGE SLUDGE 2018 Date Sampled: 07/16/18 Sample Number: BULK (JULY SAMPLE) TRC Client: REMINGTON & VERNICK ENGINEERS, INC. Engineers, Inc. Project: GCUA DIGESTOR PROJECT Mt. Laurel, NJ Project No: 244285 Figure 3 Particle Size Distribution Report 6in. 3in. 2in. in.1½ 1in. in.¾ in.½ 3/8in. #4 #10 #20 #30 #40 #60 #100 #140 #200 100 GCUA SPECIFICATION

40 PERCENT FINER PERCENT 30

0 100 10 1 0.1 0.01 0.001 GRAIN SIZE - mm. % Gravel % Sand % Fines % +3" Coarse Fine Coarse Medium Fine Silt Clay 0.0 0.0 0.0 58.4 19.2 21.5 0.9

TEST RESULTS (ASTM D 422) Material Description Opening Percent Spec.* Pass? BLACK SEWAGE SLUDGE* Size Finer (Percent) (X=Fail) #4 100.0 #10 41.6 40.0 - 100.0 Atterberg Limits (ASTM D 4318) #200 0.9 0.0 - 20.0 PL= LL= PI= Classification USCS (D 2487)= SW AASHTO (M 145)= Coefficients D90= 4.1430 D85= 3.8672 D60= 2.7004 D50= 2.3081 D30= 0.7844 D15= 0.2335 D10= 0.1559 Cu= 17.32 Cc= 1.46 Remarks *PARTICLE SIZE DISTRIBUTION MAY BE SKEWED DUE TO FIBROUS MATERIAL RETAINED ON SAND & GRAVEL- SIZED SIEVES. Date Received: 08/14/18 Date Tested: 08/29/18 Tested By: C. ZIELKE Checked By: J. BENJAMIN Title: SR GEOTECH ENGINEER * GCUA SPECIFICATION Source of Sample: SEWAGE SLUDGE 2018 Date Sampled: 08/06/18-08/ Sample Number: BULK (AUGUST SAMPLE) TRC Client: REMINGTON & VERNICK ENGINEERS, INC. Engineers, Inc. Project: GCUA DIGESTOR PROJECT Mt. Laurel, NJ Project No: 244285 Figure 4

APPENDIX IV – RD&D APPLICATION (OCTOBER 2017)

APPENDIX V – RD&D APPLICATION APPROVAL (APRIL 2018)

APPENDIX VI – PROCESS FLOW DIAGRAM

Gloucester County Improvement Authority RD&D Process Flow Diagram for Management of Biosolids Alternate Cover

*NOTE: Other Approved Cover 1. Soil/ID 27 Soil 2. Auto Shredder Residue (ASR) GCIA RD&D Process Flow Diagram for Management of Bisolids 3. Recycled Glass Aggregate (RGA) 9/19/2016 Alternate Cover

DEPARTMENT OF ENVIRONMENTAL PROTECTION PHILIP D. MURPHY Division of Solid & Hazardous Waste CATHERINE R. McCABE Governor 401 E. State Street Commissioner SHEILA Y. OLIVER PO Box 420, Mail Code 401-02C Lt. Governor Trenton, New Jersey 08625 Tel: (609) 633-1418 Fax: (609) 984-0565

January 23, 2020 Mr. Thomas H. Sullivan, Administrator Gloucester County Improvement Authority Solid Waste Complex· · 503 Monroeville Road · Swedesboro, New Jersey 08085

Re: Modified Certificate of Authority to Operate an RD&D Project Gloucester County Improvement Autl;tority Landfill South Harrison Township, Gloucester County PI# 132199 Certificate No. CT0180001

Dear Mr. Sullivan:

The Bureau of Solid Waste Permitting (Bureau) is in receipt of a letter dated September 4, 2018, submitted by Dennis K. Yoder of Remington & Verni ck Engineers on behalf of Gloucester County Utilities Authority (GCUA) and the Gloucester County Improvement Authority (GCIA), requesting a modification to the Research, Development and Demonstration (RD&D) Approval dated April 11, 2018 for the evaluation of biosolids at the referenced landfill. The purpose of the proposed modification to the RD&D project is to evaluate the effectiveness of two additional biosolids generated by GCUA as alternative daily cover material.

The Bureau has reviewed the request and understands that GCUA is in the process of upgrading its waste water treatment process. Two new anaerobic digesters were built and became . operationaUn January 2018. Following the initiation of an anaerobic digestion process, GCUA has also been experimenting by eliminating and/or replacing parts of the Orege process to control moisture content and reduce the plasticity of the. biosolids. While experimenting GCUA continued to supply biosolids meeting the alternative daily cover criteria to facility.

The Bureau has reached a final decision to approve the request to conduct the RD&D proj.ect using the two additional biosolids and is issuing the enclosed Certificate of Authority to Operate (CAO) under the authority in the Solid Waste Regulations at N.J.A.C. 7:26-l.7(f). Conditions have been incorporated within the CAO that must be complied with. The CAO is valid for one year from the issuance date. Should the evaluation program prove that the material meets the performance standards as set forth in N.J.A.C. 7:26-2A.8(b)15 and you wish to continue using the biosolids as an alternative cover beyond the expiration date of this approval, an application

The State of New Jersey is an equal opportunity employer. Printed on recycled and recyclable paper. for a modification to GCIA's solid waste facility permit must be submitted and approved by the Bureau.

If you have any questions concerning this matter, please contact Sanjay Shah of my staff by telephone at 609-984-6599, or by email at [email protected].

Very truly yours, a~ dG"X~~· Anthony ~a, Chief Bureau of Solid Waste Permitting

Enclosure c: Thomas Farrell, BSWCE John Stavash, BSWCE. John Shevlin, BSWP Stephen Boyer, BPR Jonathan Roth, Chairman South Harrison Township Environmental Commission South Harrison Township Municipal Building 664 Harrisonville Road, P.o.·Box 113 Harrisonville, New Jersey 08039 . Vince V oltaggio, Planning Director Gloucester County Department of Planning 1200 N. Delsea Drive Clayton, New Jersey 08312 Don Schneider, Environmental Coordinator Gloucester County Department of Health · 204 East Holly A venue Sewell, New Jersey 08080 George Strachan, Executive Director Gloucester Co. Improvement Authority 109 Budd Boulevard Woodbury, NJ 08096 Dennis K. Yoder Remington & Vernick Engineers 232 Kings Highway East Haddonfield, NJ 08033

Doc: Modified CAO Biosolids RD & D

Page2 of2 DEPARTMENT OF ENVIRONMENTAL PROTECTION PHILIP D. MURPHY Division of Solid & Hazardous Waste CATHERINE R. McCABE Governor 401 E. State Street ' Commissioner SHEILA Y. OLNER PO Box 420, Mail Code 40 l-02C Lt. Governor Trenton, New Jersey 08625 ·Tel: (609) 633-1418 Fax: (609) 984-0565

CERTIFICATE OF AUTHORITY TO OPERATE Research, Development & Demonstration Project

Under the provisions ofN.J.S.A. 13:1E et seq. known as the Solid Waste Management Act, this Certificate of Authority to Operate (CAO) a Research, Development & Demonstration Project is hereby issued to:

GLOUCESTER COUNTY IMPROVEMENT AUTHORITY GLOUCESTER COUNTY SOLID WASTE COMPLEX

FACILITY NAME: GLOUCESTER COUNTY IMPROVEMENT AUTHORITY LANDFILL BLOCK: 9 LOT:· 1 FACILITY ID NO.: . 132199 CERTIFICATE NO.: CT0180001 MUNICIPALITY: South Harrison Twp. COUNTY: Gloucester

This CAO is subject to compliance with all conditions specified herein and all regulations promulgated by the New Jersey Department of Environmental Protection.

This CAO shall not prejudice any .claim the State may have to riparian land, nor does it permit the registrant to fill or alter or allow to be filled or altered, in any way, lands that are deemed to be riparian, wetlands, stream encroachment areas or flood plains, or that are within the Coastal Area Facility Review Act (CAFRA) zone or are subject to the Pinelands Protection Act of 1979, nor shall it allow the discharge of pollutants to waters of this state without prior acquisition of the necessary grants, permits or approvals from the Department of Environmental Protection.

April 11, 2018 . Issuance Date Anthony Font a, Chief Bureau of Solid Waste Permitting January 23, 2020 :Modification Date

January 23, 2021 Expiration Date

The State of New Jersey is an equal opportunity employer. Printed on recycled and recyclable paper. Description

This Certificate authorizes the Gloucester County Improvement Authority (GCIA or owner) to conduct a project to evaluate the effectiveness of biosolids generated by the Gloucester County Utilities Authority (GCUA), located in West Deptford, New Jersey, as alternate daily cover. GCIA is authorized to accept no more than 100 tons of GCUA biosolids per operational day. All staging and processing of GCUA biosolids shall occur on the working face where the material will be used as a daily cover. The GCUA biosolids shall be applied as a blended material mixed with soil or other authorized alternative cover material such as ID 27 contaminated soil, automobile shredder residue or recycled glass aggregate. GCIA shall use.all GCUA biosolids received as daily cover; no GCUA biosolids may be disposed in the sanitary landfill.

Approved Application and Associated Documents

The owner shall construct and operate the facility in accordance with N.J.A.C. 7:26-1 et seq., the conditions of this CAO, and the following documents:

1. A letter dated October 27, 2017 prepared, signed and submitted by Dennis K. Yoder, along with a report dated October 2017 and entitled "Research Development and Demonstration (RD&D) Application, Gloucester County Improvement Authority, Gloucester County Landfill"; and

2. A letter dated October 19, 2017 signed by Kimberly K. Faustino of GCIA a,uthorizing Compliance Plus Service Inc., to submit an RD&D application on behalf of GCIA.

3. A letter dated September 4, 2018 prepared, signed and submitted by Dennis K. Yoder, along with a report dated September 2018 (Revised) and entitled "Modification of Research Development and Demonstration (RD&D) Application, Gloucester County Improvement Authority; Gloucester County Landfill."

Conditions of Approval

The conditions of this Certificate are found in the attached document entitled "GLOUCESTER CNTY IMPROVEMENT AUTHORITY, 132199 CT0180001 · Certificate of Authority to Operate-RD&D Exemption l.7(f) Requirements Report."

Page 2 of2 GLOUCESTER CNTY IMPROVEMENT AUTHORITY 132199 CT0180001 Certificate of Authority to Operate ,..RD&D Exemption 1.7(f) Requirements Report

Subject Item: PI 132199 -

1. · CAO REQUIREMENTS: The owner and operator shall manage the operation authorized bythis Certificate of Authority to Operate (CAO) in accordance with the requirements of this CAO and the approved application documents referenced elsewhere in this CAO. Failure to comply with the conditions of this CAO will lead to enforcement action pursuant to the Solid Waste Management Act, and may subject to a penalty pursuant to N.J.S.A. 13:1E-9. [N.J.A.C. 7:26- l.7(a)] 2. EFFECTIVE PERIOD: This CAO shall reinain effective for one (1) year from the date of modification issuance. [N.J.A.C. 7:26- l.7(a)] 3. SUSPENSION OR REVOCATION: Failure to comply with the conditions of this CAO may subject the operator/owner to suspension or revocation of the CAO in accordance with N.J.A.C. 7:26.-l.7(b) . . [N.J.A.C. 7:26- l.7(b)] 4. MODIFICATION: The Department may modify the conditions of this CAO at any time in the event that the pepartment determines that such modified conditions are necessary to comply with the requirements ofN.J.A.C. 7:26-1.7. [N.J.A.C. 7:26- l.7(a)] 5. OTHER PERMITS/APPROVALS: The issuance of this CAO and the conditions of operation identified herein shall not be interpreted as relieving the operator/owner of his responsibility to secure and maintain all other applicable federal, State and local permits or similar forms of authorization relating to the construction and/or operation of this project. [N.J.A.C. 7:26- l.7(a)] 6. NOT AN ENDORCEMENT: This authorization does not constitute an endorsement by the State of New Jersey or the New Jersey Department of Environmental Protection and may not be used for that purpose. [N.J.A.C. 7:26- l.7(a)] · 7. DEVIATIONS: This authorizations.hall remain in effect with the provision that the subject material is managed in strict compliance with the procedures as outlined herein, and without deviation from the information provided to the Department on which this authorizatio.n is based. Any deviation in the information provided to the Department on which this authorization is based will void this CAO and require a reevaluation and may make any person subject to enforcement action pursuant to N.J.S.A. 13:1E-1 et seq. known as the Solid Waste Management Act or other applicable laws and regulations. [N.J.A.C. 7:26- l.7(a)] 8. TERMINATION: The Department shall order the immediate termination of all operations at the RD&D project if it determines the project is operating in contravention of the criteria set forth in N.J.A.C. 7:26-1.7(£)2 or that termina,tion is necessary to protect human health and the environment. [N.J.A.C. 7:26~ l.7(f)9] 9. AFFECT ON ENFORCEMENT ACTIONS: This authorization is granted without prejudice and shall not affect any ongoing or future enforcement action the Department or any other agency may .take against any person. [N.J.A.C. 7:26- l.7(a)]

' Page I-1 ofl-3 GLOUCESTER CNTY IMPROVEMENT AUTHORITY 132199 CT0180001 Certificate of Authority to Operate -RD&D Exemption 1.7(f) Requirements Report

Subject Item: SWLF1218036 -

10. FINAL REPORT: Within 30 days of expiration of this CAO, GCIA shall submit a final report of the RD&D project prepared and certified by a New Jersey licensed professional engineer. The report shall include, but not be limited to:

-·a description of GCUA biosolids receipt and handling procedures and observations; - a listing of other cover materials and quantities used to blend with the GCUA biosolids; - a description of the blending and cover application methods used; - a summary and conclusions of the performance of each blend of alternate cover material as it relates to equipment/vehicle mobility and the requirements ofN.J.A.C. 7:26-2A.8(b)15; - copies of field evaluation forms; - photo documentation; and - any analytical results. [N.J.A.C. 7:26- l.7(f)7] 11. CONTINUEp OPERATION:. If GCIA wishes to use GCUA biosolids as alternate daily cover after completion of this RD&D project, GCIA must apply for and obtain a modification to its Solid Waste Facility Permit in accordance with N.J.A.C. 7:26-2. [N.J.A.C. 7:26- 1.7(£)10] 12. VARYING CONDITIONS: GCIA shall evaluate the effectiveness of the GCUA biosolids in meeting the requirements of daily cover by monitoring its use under varymg operational and weather conditions. [N.J.A.C. 7:26- 2A.8(b)19i] 13. BLENDING: The GCUA biosolids shall be blended with clean soil or other approved alternate cover material for use as daily cover. The mixture ratio shall be a minimum of one part clean soiVother approved material to one part GCUA biosolids. The GCUA biosolids shall not be mixed withZIMPRO sludge to be used as an alternate daily cover. [N.J.A.C. 7:26- l.7(a)] 14. DAILY RECEIPT LIMIT: No more than 100 tons of GCUA digested biosolids treated with or without proprietary Orege process shall be accepted on a daily basis. [N.J.A.C. 7:26- l .7(f)2iv] 15. STAGING: The GCUA biosolids shall be placed only near the active. working face on lined areas of the landfill. Erosion controls shall be utilized to prevent runoff from the GCUA biosolids entering perimeter stormwater controls. Up to 100 tons of GCUA biosolids may be staged overnight on lined areas of the landfill near the working face.· All GCUA biosolids staged overnight shall be used for alternate cover material the next day. [N.J.A.C. 7:26- l.7(a)] 16. EVALUATION PROGRAM: The evaluation program shall meet the requirements for RD&D projects as set forth at N.J.A.C. 7:26-1.7(£). the program shall evaluate the cover material in actual use at the landfill. The GCUA biosolids alternate daily cover blends shall be evaluated every operating day that the material is in use and exposed. The evaluation shall be performed by an individual qualified to do so. An evaluation form included in the application documents, or its equivalent, shall be completed by a qualified individual at least once each operating day. Photos shall be taken to document observations. No reduction in evaluation frequency shall be made without the consent of the Bureau of Solid Waste Permitting .. A New Jersey licensed professional engineer (NJPE) shall oversee the project to the extent that the NJPE can prepare and certify the final report required by this CAO. [N.J.A.C. 7:26- L7(f)]

Page I-2 ofl-3 GLOUCESTER CNTY IMPROVEMENT AUTHORITY 132199 CT0180001 Certificate of Authority to Operate -RD&D Exemption 1.7(f) Requirements Report

Subject Item: SWLF1218036 -

17. DISPOSAL PROHIBITION: All GCUA biosolids received by GCIA must be used as alternate daily cover in accordance with the requirements ofthis CAO. In no case shall GCUA biosolids be disposed in the GCIA landfill as waste. In the event that any GCUA biosolids received by GCIA cannot be used as alternate cover in accordance with this CAO, the unused GCUA biosolids must be shipped off-site to a facility that is authorized to receive the biosolids. [N.J.A.C. 7:26- l.7(a)] 18. RECEIPT HOURS: The GCUA biosolids shall be received at the landfill facility only during normal landfill operating hours.· [N.J.A.C. 7:26- l.7(a)] 19. MONTHLY REPORT: GCIA shall submit a monthly report to the Division of Solid & Hazardous Waste for each calende.r month of operation. Each monthly report shall be due on the twentieth day of the following calendar month. The mon.thly report shall include, but not limited to, the quantity of · GCUA biosolids received during the month; the quantity of GCUA biosolids used as daily and intermediate cover during the month; copies of all evaluation forms completed during the month; and a, narrative summarizing the progress ofthe RD&D project and problems encountered or changes needed. [N.J.A.C. 7:26- L 7(f)7] 20. OBJECTIVE: The objective of the RD&D project is to dem~nstrate whether GCUA biosolids .blended with various other cover materials can meet the criteria for alternate daily and intermediate cover material specified in N.J.A.C. 7:26-2A.8(b)15(i) through (v). [N.J.A.C. 7:26- 2A.8(b)l5]

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