2903_INSP_20180205

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 5

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Davidson
Closed
MSWLF X HHW White
goods Incin T&P FIRM PERMIT NO.: 2903
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 02/05/2018 Date of Last Inspection: 04/17/2002

FACILITY NAME AND ADDRESS:
City of Lexington Landfill - Closed
Valley Avenue
Lexington, NC 27292

GPS COORDINATES: N: 35.832962° W: -80.217141°

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Roger Jones, Public Services Manager
Telephone: [phone] (office); 336-240-1952 (mobile).
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
28 W. Center Street
Lexington, NC 27292

PARTICIPANTS:
Roger Jones, Public Services Manager – City of Lexington
Susan Heim, Environmental Senior Specialist – Solid Waste Section

STATUS OF PERMIT:
Closed

PURPOSE OF SITE VISIT:
Post-closure Inspection

STATUS OF PAST NOTED VIOLATIONS:
None

OBSERVED VIOLATIONS:

1. 15A NCAC 02C .0108(k) states: “All non-water supply wells, including temporary wells, shall be secured with a
locking well cap to ensure against unauthorized access and use.”

The City of Lexington is in violation of 15A NCAC 02C .0108(k) for failure to secure groundwater monitoring
wells against unauthorized access and use.

The following deficiencies were observed during this inspection, with regard to securing groundwater monitoring
wells:
• MW-2 and MW-3 had broken hinges on the caps of the steel casings;
• MW-2, MW-3, MW-4, MW-6, MW-7, MW-7D, MW-8, MW-9, MW-10, MW-10D, MW-12 either had a lock
on the cap that was not functional or no lock at all.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 5

To achieve compliance, the City of Lexington must secure all groundwater monitoring wells with a locking cap.

2. 15A NCAC 02C .0108(o) states: “Each non-water supply well shall have permanently affixed an identification plate.
The identification plate shall be constructed of a durable, waterproof, rustproof metal or other material approved by
the Department as equivalent and shall contain the following information:
(1) well contractor name and certification number;
(2) date well completed;
(3) total depth of well;
(4) a warning that the well is not for water supply and that the groundwater may contain hazardous materials;
(5) depth(s) to the top(s) and bottom(s) of the screen(s); and
(6) the well identification number or name assigned by the well owner.”

The City of Lexington is in violation of 15A NCAC 02C .0108(o) for failure to ensure that all groundwater
monitoring wells have a permanently affixed identification plate constructed of a durable, waterproof,
rustproof metal or other approved material that includes all of the information required by this rule.

At the time of this inspection, MW-10D had no rustproof metal identification plate affixed to the steel casing.

To achieve compliance, the City of Lexington must affix a permanent metal identification plate, as specified in
15A NCAC 02C .0108(o), to the steel outer casing of MW-10D.

3. 15A NCAC 13B .0505(5)(b) states: “Surface water shall not be impounded over or in waste.”

The City of Lexington is in violation of 15A NCAC 13B .0505(5)(b) for allowing surface water to be impounded
over waste.

During this inspection, large areas of ponded water were observed on the top of the landfill cap, several of which were
found to be 6” or greater in depth.

To achieve compliance, the City of Lexington must repair areas of the cap where settling has occurred and
eliminate the depressions that permit water to pond over waste.

4. 15A NCAC 13B .0510(c) states, in part: “When a solid waste disposal site has been closed in accordance with the
requirements of the Division, future necessary maintenance and water quality monitoring shall be the responsibility of
the owner and the operator.”

The City of Lexington is in violation of 15A NCAC 13B .0510(c) for failing to maintain the integrity of the cap
of the closed MSW landfill.

Much of the landfill cap was not inspected due to the preponderance of briars, trees and other woody vegetation
growing on top of the landfill and penetrating the landfill cap, making it impassable. Side slopes were observed to be
steep and wooded, with evidence of erosion in some areas.

To achieve compliance, the City of Lexington must perform maintenance to restore the integrity of the closed
MSW landfill cap.

SUMMARY OF CORRECTIVE ACTION REQUIRED:

1. By March 31, 2018, ensure that all waste, including scrap tires and white goods, is collected from the closed
landfill site and disposed of properly.
2. By April 30, 2018, mow, bush hog and clear the entire cap of the closed MSW landfill to remove underbrush,
kudzu and small woody vegetation.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 5

3. By April 30, 2018, locate and mark the waste boundaries of the closed MSW landfill with permanent edge-of-waste
markers.

4. By April 30, 2018, submit a plan for post-closure maintenance of the closed MSW landfill that will address the
following:
• repair of the landfill cap to eliminate the depressions that are currently impounding water over waste
within the disposal area;
• maintenance of the landfill cap and required final landfill cover;
• management of trees growing on the landfill cap in a phased approach, including the removal of small
trees and root systems and repair of the cap; and, monitoring of large trees and removal of dead or
diseased trees;
• prevention of erosion and sedimentation, and the monitoring and maintenance of any erosion control
devices and sediment ponds that are a part of the facility;
• repair and upgrade the existing groundwater monitoring wells to ensure compliance with 15A NCAC 02C
.0108(k) and (o), as described above in Observed Violations 1 and 2 above.

The plan will be reviewed by the Solid Waste Section and, once approved, will be implemented by the City
of Lexington according to the time table set forth. Please submit the plan to Susan Heim, Environmental
Senior Specialist, NCDEQ-DWM, Winston-Salem Regional Office, 450 W. Hanes Mill Road, Winston-
Salem, NC 27105.

View of a presumed
section of landfill
slope with
underbrush, trees
and other woody
plants, along with
scrap metal (center)
and tires
(foreground).
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 5

ADDITIONAL COMMENTS

1. The facility is a closed, unlined sanitary landfill that ceased accepting waste sometime in 1990-91.
2. The landfill is located northeast of the intersection of US 64 and Valley Avenue, and is bordered by railroad tracks
on the north and a creek on the south.
3. The facility is secured by means of a locked, gated entrance at the rear of the parking lot of Morton Buildings, Inc.,
located at 615 E. US Hwy. 64. In addition, topography, the creek and the railroad tracks further limit access to the
site.
4. The facility is performing annual groundwater monitoring, as approved on January 21, 2016 by Jaclynne
Drummond, Hydrogeologist, Solid Waste Section. This approval for annual monitoring also included approval to
remove monitoring wells MW-4, MW-5 and MW-12 from the monitoring program.
5. The groundwater monitoring system consists of 13 wells, including the three listed in comment 3 above. 12 of
these wells are located south of the railroad tracks. MW-11 is located on the north side of the railroad right-of-way
and was not observed. However, all of the other 12 wells were inspected. Many of the wells were difficult to reach,
based on topography and lack of regular maintenance of the areas surrounding the wells and of the trails used to
access them. Please ensure that all monitoring wells are accessible and that all vegetation is removed from
the area around the wells to enable an inspection of the well casing, cap, identification tag and concrete pad.
The item(s) 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.
View of another
area presumed to
be the slope of the
closed landfill.
Note woody growth
throughout, as
well as scattered
tires and plastic
bottles.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 5

A regular maintenance schedule should be established to ensure that access is maintained. Please ensure that
any deficiencies in the monitoring wells are corrected, as required by 15A NCAC 02C .0108(k) and (o). (See
Observed Violations section of this report for additional information.)
6. No edge-of-waste markers were observed that would delineate the waste disposal boundary of the landfill.
7. A large number of mature trees, as well as underbrush and other woody plants, were observed throughout the
landfill area. However, because no edge-of-waste markers were found that would delineate the waste boundary, it
is not possible to determine which trees were actually located on top of waste, nor is it possible to inspect the
landfill cap to ensure its integrity and effectiveness. Please perform maintenance that will locate existing edge-
of-waste markers or, if no markers exist, install edge-of-waste markers that clearly and accurately indicate
the waste disposal boundary of the landfill.
8. Several locations were observed where scrap tires, white goods and scrap metal had been dumped or stored on the
ground at the site. Please ensure that all waste, including scrap tires, white goods and scrap metal observed
during this inspection, are collected and disposed of properly.

Please contact me if you have any questions or concerns regarding this inspection report.

__________________________________________ Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative

Sent on: February 26, 2018 to
Roger Jones.
X Email Hand delivery US Mail

Copies: Deb Aja, Western District Supervisor – Solid Waste Section
Perry Sugg, Hydrogeologist – Solid Waste Section