7304_NOV_20201021

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
October 30, 2020
CERTIFIED MAIL 7016 1970 0000 9291 8532
RETURN RECEIPT REQUESTED
Erik Seibold
Republic Services of North Carolina, LLC
d.b.a. Upper Piedmont Regional Landfill
9650 Oxford Road
Rougemont, NC 27572
SUBJECT: Notice of Violation
Compliance Inspection Report
Upper Piedmont Regional Landfill
7304-MWSLF-1997
Person County
Dear Mr. Seibold:
On October 21, 2020, Davy Conners, representing the State of North Carolina, Division of Waste
Management Solid Waste Section (Section), inspected the above referenced facility for
compliance with North Carolina solid waste statutes and rules. Erik Seibold and Matt Einsmann
were present and represented Upper Piedmont Regional Landfill during this inspection. The
following violation was noted:
A. 15A NCAC13B .1626 (8)(d), "Leachate shall be contained within a lined disposal cell or
leachate collection and storage system."
Upper Piedmont Regional Landfill is in violation of 15A NCAC 13B .1626 (8)(d) in that
leachate had not been contained within the collection system. On October 20, 2020, Matt
Einsmann notified the Section of a leachate release that occurred in the leachate
containment tanks and secondary containment. According to Mr. Einsmann and Mr.
Seibold, early morning on Monday October 19, 2020, Upper Piedmont was notified of a
leak in their leachate tanks. When Upper Piedmont Staff arrived on site, Tank A and 8
were full of leachate and had overflowed into the secondary containment, which had
approximately 4 inches of freeboard remaining. Two leachate releases beyond the
D_EQ1Aj
NORTH CAROLINA
department of E—irenmeetal a".1ity
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Upper Piedmont Regional Landfill
Notice of Violation
Page 2 of 4
October 30, 2020
containment system were identified. The first release was from a hole approximately 25
feet above the ground in Tank B, which due to static head in the leachate tank, was causing
leachate to flow out of the hole beyond the secondary containment system. The second
leachate release came from a leak between the flange and the secondary containment
wall where the leachate inlet pipe enters the leachate storage system. This leak was of
the leachate that had overflowed into the secondary containment not from the inlet pipe
itself. Approximately 200 gallons of leachate were released from both leaks.
Upper Piedmont responded to the releases by constructing an earthen dam to contain the
leachate. The leachate in the tanks and secondary containment was pumped down over
the course of two days. Additionally, the leachate that had been contained within the
earthen dam was pumped. By Tuesday afternoon the leachate levels in Tank B had been
pumped below the holes and they were patched temporarily until they could be repaired.
During the October 21, 2020 inspection, leachate was observed in the following areas: 1.
saturating the ground surrounding the leachate storage system, 2. in a drainage ditch
between the office building and the tanks, and 3. on the concrete pad next to the leachate
storage system. The following actions had been taken to contain the leachate in these
areas, respectively: an earthen dam had been built surrounding the storage system and
the area had been pumped of most of the leachate, an earthen dam had been built to stop
leachate from flowing into a concrete culvert and the area had been pumped of most of
the leachate, and the concrete pad had been pumped of most of the leachate.
On October 22, 2020, Upper Piedmont submitted the Site Sampling Plan to the Section,
which was approved the same day.
Based upon the foregoing, Upper Piedmont Regional Landfill shall come into compliance with all
requirements of the regulations in 15A NCAC 13B .1626 (8)(d) by completing the following:
Corrective Actions
The Site Sampling Plan has been submitted to and approved by the Section. The Site
Sampling plan must be implemented within 7 days of approval.
2. Within 10 business days after receiving the analytical results from the laboratory, submit
documentation regarding the sampling event which shall include the following:
D_EW
NORTH CAROLINA Q
Aj
ilupadmu,I ui E—irp 0. 1 quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Upper Piedmont Regional Landfill
Notice of Violation
Page 3 of 4
October 30, 2020
a. A summary of the leachate release, actions taken to address the release, and the
release assessment;
b. A map/aerial photo depicting the sampling locations;
c. A table of the surface water analytical results compared to the NCDWR Surface
Water Quality Standards & Protective Values;
d. A table of the subsurface soil analytical results compared to the NCDEQ
Preliminary Soil Remediation Goals (PSRGs). Both the Residential Health Based
and the Protection of Groundwater PSRGs must be met;
e. The associated laboratory reports from the NC certified laboratory including the
chain of custody and QA/QC results;
f. The sampling methodology, if different from the proposed plan; and
g. Conclusions and recommendation
3. Submit the results to Ervin Lane, Hydrogeologist, 1646 Mail Service Center, Raleigh, NC
27699-1646, [e-mail], 919-707-8288, and Davy Conners, Senior
Environmental Specialist, [e-mail], 919-621-3685.
The violations listed above were observed by Section staff and require action on behalf of the
facility in order to come into or maintain compliance with the Statutes, Rules, and/or other
regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22,
an administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid
Waste Laws, Regulations, Conditions of a Permit, or Order under Article 9 of Chapter 130A of the
N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to
enforcement actions including penalties, injunction from operation of a solid waste management
facility or a solid waste collection service and any such further relief as may be necessary to
achieve compliance with the North Carolina Solid Waste Management Act and Rules.
Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct
a follow-up inspection(s) to verify that the facility has completed the requirements of this Notice
of Violation.
D_EW
NORTH CAROLINA Q
Aj
ilupadmu,I ui En irp 0. 1 quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Upper Piedmont Regional Landfill
Notice of Violation
Page 4 of 4
October 30, 2020
If you have any questions, please call me at [phone] or e-mail [e-mail].
Sincerely,
Digitally signed by Davy Conners
DN: cn=Davy Conners, o=Division of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2020.10.30 13:39:16-04'00'
Davy Conners
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
copies: Ed Mussler, Section Chief
Jason Watkins, Field Operations Branch Head
Andrew Hammonds, Eastern District Supervisor
Ervin Lane, Hydrogeologist
Amanda Thompson, Environmental Senior Specialist
Jessica Monte, Compliance Officer
Amanda Freeman, Compliance Officer
Matt Einsmann, Republic Services
NORTH GAROLINA
ilapaamant Oi EnvironmanGl quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200