2903_INSP_20180523

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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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: 05/23/2018 Date of Last Inspection: 02/05/2018

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:

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.”
Time did not permit the inspection of all monitoring wells during this site visit. However, Mr. Jones stated
that all monitoring wells had been fitted with new locks, and that repairs to well caps had been made to
prevent unauthorized access.

2. 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
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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(6) the well identification number or name assigned by the well owner.”
Time did not permit the inspection of all monitoring wells during this site visit. However, Mr. Jones stated
that all monitoring wells had been fitted with rustproof identification plates.

3. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0505(5)(b) states: “Surface water shall not be
impounded over or in waste.” During this inspection, a large portion of the landfill cap was observed to have
been mown. Woody plants and trees had been removed; and, brush limbs were staged in piles on the top of
the landfill cap. Areas of ponding water had been made accessible. However, continuing heavy rains over the
past month had made access with heavy equipment impossible. Mr. Jones stated that he planned to have
repairs underway as soon as the facility dried out enough to permit work to begin.

4. CORRECTIVE MEASURES IN PROGRESS: 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.” Work to re-establish the
integrity of the landfill cap are underway at the facility. Most of the top of the landfill cap has been cleared of
brush and trees, and Mr. Jones stated that work will continue as the conditions on the ground and the
weather permit.

SUMMARY OF CORRECTIVE ACTION REQUIRED:

During this inspection, the following required corrective actions were discussed:
1. Removal of scrap tires and white goods from landfill property;
2. Completion of bush hogging and clearing of the top of the landfill cap;
3. Assessment and repair of landfill slopes;
4. Determination of the waste boundary and installation of permanent edge-of-waste markers;
5. Repair the landfill cap to eliminate the depressions that are impounding water over the waste within the landfill;
6. Repair and maintain drainage ditches, sediment ponds, and any other erosion control devices that are part of the
facility;
7. Procedures for the management of trees on the landfill cap;
8. Reinspection of the monitoring wells for compliance with well construction standards to resolve previously
observed violations listed as #s 1 and 2 above.
Mr. Jones explained that continuing heavy rains during the month of May had stopped clearing of the landfill from
proceeding. He added that city crews had spent several weeks clearing the top of the landfill, and that the areas
remaining to be cleared were too wet to support heavy equipment at this time. He stated his intention to resume work
when the weather and ground conditions would permit. Mr. Jones also noted that crews had so far been unable to
remove the scrap tires and white goods observed on the landfill property for the same reason.

The actual footprint of the landfill was also discussed. Mr. Jones stated that he had obtained some information from a
city employee who had worked at the landfill site while it was operating. He explained that, using this information,
along with historical aerial photography and the existing topography of the land, he would use an augur to probe areas
assumed to be near the waste boundary. In that way, he would be able to establish the edge-of-waste and install the
required markers.

Regarding the trees growing on the landfill cap, Mr. Jones proposed the following:
1. Remove all woody plants, dead trees, and all live trees less than 6” in diameter, along with their root
systems, from the landfill top and repair damage to the landfill cap that results;
2. Inspect and monitor the remaining trees quarterly; remove any large trees found to be dead, damaged or
diseased at that time; repair and restore the cap as needed afterwards;
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Division of Waste Management
Solid Waste Section
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3. Along with monitoring the condition of trees, inspect and monitor the condition of the side slopes, remove
brush and any other woody plant growth, repair any erosion damage and ensure the integrity of the landfill
cap;
4. Bush hog and maintain the landfill so that additional trees and woody plants are not permitted to become
established on the cap.

By June 30, 2018, the City of Lexington will compile a list of specific corrective actions to be taken, along with a
date for the completion of each. In addition, the City of Lexington will develop a list of procedures that will be
used to monitor, repair and maintain the closed landfill unit as required by 15A NCAC 13B .0510(c), including
the frequency with which these procedures must be performed. This documentation will be submitted to the
Solid Waste Section on or before June 15, 2018. Please submit via email to Susan Heim, Environmental Senior
Specialist, at [e-mail].

OBSERVED VIOLATIONS:

No new violations were observed during this inspection.

ADDITIONAL COMMENTS

1. The purpose of this inspection was to observe the maintenance work performed since the previous inspection on
February 5, 2018.
2. Much of the top of the landfill cap had been bush hogged and mowed. Piles of brush and trees were staged for
removal when truck access becomes possible. Most areas of the landfill top were visible, although some areas were
still too wet to clear.
3. Several areas of ponding water were observed, and Mr. Jones stated that he hoped removal of many of the trees
would allow sunlight help to dry the area sufficiently to allow heavy equipment to do additional clearing before
beginning the task of filling the low areas that are holding water. He added that the city is considering hiring a
contractor to do much of the remaining clearing and repair work on the site.
4. Some discussion took place regarding grinding operations, and several sites outside of the actual landfill footprint
were considered as viable possibilities. Ground wood waste cannot be disposed of onsite and must be removed
from the landfill facility.
5. Mr. Jones stated that no edge-of-waste markers were found during the clearing work that would delineate the waste
disposal boundary of the landfill. He voiced his intention to probe the site to locate the waste boundary. (See the
Summary of Corrective Action Required section of this report for additional information.)
6. Monitoring wells were not inspected during this site visit due to time constraints. Mr. Jones stated that most of the
upgrades and repairs required in the Observed Violations, issued February 26, 2018, had been completed. Several
wells could be seen during the tour of the site. New markers had been installed and, where possible, access had
been cleared. However, an inspection of the entire groundwater monitoring system will be required to clear these
two violations.
7. The abandoned scrap tires and white goods observed during the previous inspection on February 5, 2018 remain,
due to the inability to get vehicles and equipment into some areas of the landfill,

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
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View from the
access roadway
looking southeast
across the top of
the landfill. Piles
of the cleared trees
and brush and the
line of mature
trees growing on
the side slopes can
be seen in the
background.
One of several areas on
the top of the landfill
where water is ponded.
These areas are still too
soft and wet to access with
the equipment necessary
to complete clearing and
repair operations.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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Please contact me if you have any questions or concerns regarding this inspection report or the information that must be
submitted to me by June 30, 2018. If additional site visits may be arranged if needed.

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

Sent on: June 1, 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
View from the
landfill top
looking down
over the side
slope where a
monitoring well
is located. New
markers have
been installed to
indicate the path
to the well.