2906_INSP_20180413

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined
MSWLF X LCID YW Transfer X Compost SLAS COUNTY: Davidson
Closed
MSWLF X HHW X White
goods X Incin T&P FIRM PERMIT NO.: 2906
CDLF X Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 04/13/2018 Date of Last Inspection: 12/05/2017 and 12/19/2017

FACILITY NAME AND ADDRESS:
Davidson County Integrated Solid Waste Management Facility
220 Davidson County Landfill Road
Lexington, NC 27292

GPS COORDINATES: N: 35.85281° W: 80.17620°

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Rex Buck, Public Services Director
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
P. O. Box 1067
Lexington, NC 27293-1067

PARTICIPANTS:
Rex Buck, Public Services Director – Davidson County
Charlie Brushwood – Davidson County
Mike Lankford, Equipment Operator – Davidson County
Pieter Scheer – Smith Gardner, Inc.
Joan Smyth – Smith Gardner, Inc.
Susan Heim, Environmental Senior Specialist – Solid Waste Section

STATUS OF PERMIT:
2906-MSWLF-1994: Closed
2906-MSWLF-2008: Life of Site Permit Issued 03/12/2018
2906-TRANSFER-2013: Life of Site Permit Issued 03/12/2018
2906-HHW: Issued 03/12/2018; Expires 05/28/2023

PURPOSE OF SITE VISIT:
Partial Inspection

STATUS OF PAST NOTED VIOLATIONS:

1. CORRECTIVE MEASURES IN PROGRESS: 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.” On February 22, 2018, a response letter was received from Madeline German, Smith Gardner, Inc., stating
that locks had been installed on most monitoring wells that had been lacking them. For those wells requiring other
upgrades or repairs, locks will be installed when well caps are in place.

2. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 02C .0108(l) states: “All non-water supply wells shall
be equipped with a steel outer well casing or flush-mount cover, set in concrete, and other measures sufficient to
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 10

protect the well from damage by normal site activities.” The February 22, 2018 response letter from Madeline
German states that repairs and upgrades to the monitoring wells that had been noted as having deficiencies in the
well casing and concrete pad will be addressed during activities relating to the new Phase 2 construction.

3. CORRECTIVE MEASURES IN PROGRESS: 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.”
Madeline German’s response letter of February 22, 2018 states that all monitoring wells have had the required
permanent identification tags installed or updated, with the exception of LFG-9 and any deficient wells that
require repair or upgrade.

OBSERVED VIOLATIONS:

1. 15A NCAC 13B .1626(2)(a) states: “the owners and operators of all MSWLF units must cover disposed solid
waste with six inches of earthen material when the waste disposal at the end of each operating day, or at more
frequent intervals if necessary, to control disease vectors, fires, odors, blowing litter, and scavenging.”

Davidson County is in violation of 15A NCAC 13B .1626(2)(a) by inadequately covering disposed solid
waste at the end of each operating day.

During this inspection, uncovered and inadequately covered waste was observed in a large area surrounding the
working face. It appeared that waste had been exposed as a result of maneuvering vehicles and operating
equipment during daily operations.

Uncovered waste observed in areas
surrounding the current working face
(left).
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 10

2. 15A NCAC 13B .1626(2)(c) states: “Areas which will not have additional wastes placed on them for 12 months
or more, but where final termination of disposal operations has not occurred, shall be covered with a minimum of
one foot of intermediate cover.”

Davidson County is in violation of 15A NCAC 13B .1626(2)(c) by failing to maintain 12” of intermediate
cover to a portion of the northern and northeastern slopes of the active landfill and on the top of the
landfill cap where final elevations have been achieved but closure has not taken place.

Upon inspection, these side slopes appeared to have had seed applied over exposed waste. Partially exposed waste
was clearly visible over the entire area that had been seeded; and, large pieces were observed protruding upwards
through the thin layer of seeding material. The top of the landfill cap was heavily rutted and damaged by heavy
equipment, possibly associated with the installation of additional landfill gas extraction wells along the top of the
slopes. Vegetative cover had been eliminated from many areas completely, and deep depressions were observed
in several areas that would allow water to pond on top of the waste disposal area. Exposed waste was also
observed on the top of the landfill cap and in excavated areas surrounding the newly installed landfill gas
extraction wells along the top of the landfill side slopes.

Exposed waste in the area
south of the current working
face.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 10

3.

TOP RIGHT: a recently installed landfill gas
extraction well with the well excavation unrepaired and
uncovered waste remaining.

TOP LEFT: uncovered waste visible through seeding
on the northern slope of landfill.

MIDDLE LEFT: top of the landfill cap disturbed and
rutted from equipment use, vegetative cover eliminated,
exposed waste mixed with soil.

BOTTOM: two leachate seep repairs on the south slope
of the landfill. Note exposed waste mixed with soil
cover.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 10

SUMMARY OF CORRECTIVE MEASURES REQUIRED:

1. Immediately cover all exposed waste in the operations area surrounding the working face with at least 6” of
clean soil.
2. Assess the extent of repairs required for the landfill, including:
a. the application of 12” of intermediate cover to the inactive disposal area;
b. regrading and reseeding the side slopes of the inactive disposal area;
c. repairing and covering the excavation areas surrounding each of the recently installed landfill gas
extraction wells;
d. repairing, regrading, covering and seeding the top of the landfill cap.
3. By April 27, 2018, submit a plan listing the corrective actions needed and a schedule for completing each. The
plan may be developed as a list of bullet points with completion dates associated with each. The plan should be
submitted to:

Susan Heim, Environmental Senior Specialist
NCDEQ – DWM – Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105

4. The plan will be reviewed and approved by the Solid Waste Section, and Davidson County will be responsible
for implementing it as approved.

ADDITIONAL COMMENTS

1. This partial inspection was made following a pre-construction meeting for Current landfill operations were observed
to be taking place in Phase 2, Area 2, Cell 2. This cell began receiving waste in August 2016.
2. The working face of the landfill was observed to be small and manageable. Small stockpiles of clean cover soil
were being staged near the working face by a grading contractor hired by the county for the job. Mr. Lankford
explained that the county’s pan had been down since early December, and that landfill staff had been using a loader
to haul clean soil from the borrow area for some time. Mr. Brushwood added that a new engine for the pan had been
ordered following recent action to approve the purchase. He expressed his hope that the truck would be operational
again within the next week or 10 days.
3. The operations area surrounding the working face was large and undefined. Vehicle and equipment maneuvering
had resulted in waste being pulled up through the soil cover and left exposed. Mr. Lankford stated that staffing
levels had not been adequate to maintain anything other than the working face for several weeks. (See Observed
Violations section of this report for additional information.)
4. Portions of the northern and northeastern slopes of the landfill had been seeded, apparently without the required 12”
of intermediate cover being applied beforehand. From a distance, exposed waste could be seen protruding up out of
the face of the slope. At close range, exposed waste was visible beneath the thin cover of seeding material. (See
Observed Violations section of this report for additional information.)
5. A few woody plants were observed to be growing along the slope drains and the perimeter ditch of the active
landfill unit. Ensure that all woody vegetation is removed from the landfill cap promptly, so that the function
of the drains and ditch are not impeded and that the landfill cap is not damaged.

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.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 10

6. Four repair areas were observed along the southern slope of the landfill. Mr. Buck confirmed that leachate seeps had
been discovered and repaired. Mr. Brushwood stated that the seeps were likely the result of water impounding in the
deep depressions observed on the top of the landfill cap. He added that he would speak with Mr. Lankford, who had
returned to the working face to resume operations, to ascertain whether the seeps had been properly excavated
before being covered with soil. Waste was observed to be mixed with the soil in these repair areas. (See Observed
Violations section of this report for additional information.)
7. Access roadways are of all-weather construction. Several areas of the internal roadway system were observed to be
rutted and in need of repair. After the inspection, Mr. Brushwood stated that he would ensure that repairs were made
promptly to avoid further deterioration of the road system. Please ensure that maintenance is performed on
access roadways as necessary.
8. The HHW collection area is surrounded by a fence and secured by a gate that is kept locked when the facility is not
in operation. During this inspection, side gates allowing access to the HHW collection area were open, and one gate
panel appeared to be missing from the site. Ensure that the fence and gates associated with the HHW collection
area are intact, in good repair and functioning properly so that the site is not accessible by unauthorized staff
or members of the public.

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: April 20, 2018 to Zeb
Hanner, County Manager.
X Email Hand delivery US Mail X Certified No.
7011 1570 0001 8545 6001

Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section
Deb Aja, Western District Supervisor – Solid Waste Section
Jessica Montie, Compliance Officer – Solid Waste Section
Perry Sugg, Hydrogeologist – Solid Waste Section
Ming-Tai Chao, Permit Engineer – Solid Waste Section
Rex Buck – Davidson County
Charlie Brushwood – Davidson County
Steven Sink – Davidson County