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HomeMy WebLinkAbout3420_INSP_20180618FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 6 UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Forsyth Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 34-20 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill X DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: June 18, 2018 Date of Last Inspection: July 13, 2017 FACILITY NAME AND ADDRESS: OmniSource Southeast Industrial Landfill 1426 W. Mountain Street Kernersville, NC 27284 GPS COORDINATES: N: 36.142173° W: -80.102696 ° FACILITY CONTACT NAME AND PHONE NUMBER: Name: James Winegar, Environmental Manager Telephone: (919) 796-3023 (mobile) Email address: jwinegar@omnisourcese.com FACILITY CONTACT ADDRESS: James Winegar, Environmental Manager OmniSource Southeast 2233 Wal-Pat Road Smithfield, NC 27577 PARTICIPANTS: James Winegar, Environmental Manager – OmniSource Southeast Jeff Hall – OmniSource Southeast Deb Aja, Western District Supervisor – Solid Waste Section Susan Heim, Environmental Senior Specialist – Solid Waste Section STATUS OF PERMIT: Permit to Operate Auto Shredder Residue Reclamation Operation issued to Atlantic Scrap and Salvage LLC: 9/2/2005. Permit to Operate Expired: 9/2/2008. Permit Application for OmniSource Southeast submitted: 5/27/2014. Revised Application for Permit to Operate/Permit to Close Submitted: 10/2/2017; currently under review by the Solid Waste Section. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS: None 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 2 of 6 ADDITIONAL COMMENTS 1. The facility was originally permitted under Atlantic Scrap and Processing LLC to operate an auto shredder residue (ASR) reclamation operation, removing waste from the existing ASR industrial landfill and processing it to recover metals and returning the residual material to the landfill. 2. Atlantic Scrap and Processing LLC was acquired by OmniSource Southeast, who now owns and operates the facility. OmniSource contracted with Second Pass LLC to process the ASR from the landfill and recover additional metals. Based on information provided during this inspection, it is understood that mining and metal recovery operations at the landfill ceased in March 2018. Currently, remaining stockpiles of reprocessed waste are being moved back into the landfill in preparation for closure. It is recommended that a meeting of OmniSource staff and Solid Waste Section staff take place as soon as possible to discuss the closure process and post-closure care requirements. Closure operations should not begin until a closure plan is approved by the Permitting Branch. Please contact Permit Engineer Ming-tai Chao to schedule a meeting. 3. OmniSource has been actively working with Permitting Branch staff to acquire a permit for the facility in their name. Most recently, an application was submitted by OmniSource in October 2017 for a permit to operate/close the facility. This application is currently under review by the Solid Waste Section. 4. The landfill was originally permitted to handle and process only materials recovered from the ASR landfill and only the residual from these operations was allowed to be returned to the landfill for disposal. Mr. Winegar stated that OmniSource has always maintained a strict separation between the landfill operations and the salvage yard operations. He pointed out the auto shredding machinery in operation in the scrap yard, and explained that all ASR generated there is transported offsite for additional processing. 5. The landfill is located on the northern end of the OmniSource Kernersville property, which is secured by fencing and gates. The landfill is accessed through the main gate, which is kept locked except during business hours. Signage was observed at the facility entrance. 6. Groundwater monitoring has been taking place on a semi-annual basis as required. Records for the two semi- annual sampling events for 2017 were reviewed and verified. The first sampling event took place on April 12, 2017, and included 4 monitoring wells and 4 surface water monitoring points. The second sampling event took place on October 30 and December 1, 2017. During the second sampling event, an additional surface water monitoring point was added in an effort to clarify the source of the exceedances of some metals and volatile organic compounds that have been detected as a result of the ongoing groundwater monitoring program. The December 1st sampling took place to re-sample the surface water points due to the inconsistent findings of the October 30th event. The report stated that analysis of the December 1st re-sampling refuted the October 30th data and showed that results are indeed consistent with historical data. Groundwater monitoring data is being reviewed by the Environmental Compliance Branch. 7. Following the inspection, Mr. Winegar provided a tonnage report covering landfill operations for the period July 1, 2017 through the conclusion of operations in March 2018. A review of the report indicated the following totals for this time period: 50,322 tons of material were removed from the landfill unit for processing; 7,651 tons of material were recovered during processing; and, 36,553 tons of residual waste were returned to the landfill for disposal. Mr. Winegar explained that the diminishing recovery rate evident in the tonnage figures ultimately led to the decision to cease mining and recovery operations at the landfill and close the facility permanently. 8. The following information, requested after the previous inspection on July 13, 2017, has not been received by the Solid Waste Section to date: a. the process by which the liquid generated at the end of the wet processing line was captured and managed; b. the actual location of the western berm of the landfill; c. the location and condition of all catch basins associated with the landfill reclamation operation; d. clarification about the construction and purpose of the berm that separates the fill area from the drainage ditch on the east side of the landfill; e. erosion and sedimentation control measures in place for the area surrounding the fore bay, sediment basin and spillway; f. the separation and management of stormwater and leachate at the landfill facility; g. the actual location of the waste boundary of the landfill. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 6 9. The processing area for the landfill was observed to be completely shut down. Machinery from the wet processing area was in the process of being dismantled and removed from the site. A section of the dry processing plant had already been disassembled and removed. A large stockpile of ASR was observed throughout the processing area and the material storage areas located directly to the south. Mr. Hall indicated that he had been working to move this material to the landfill since processing operations had been halted. 10. The landfill itself is accessed from the south. In this area, the top of fill is close to the grade level of the property surrounding the landfill unit. The western slopes of the landfill were not inspected because they were not accessible. Mr. Hall stated that he had been moving the residual waste from the processing area back to the landfill, and had been working from west to east. The perimeter road that had provided access to the north side of the landfill had been covered with ASR. The silt fence that had previously bordered the western perimeter access roadway was not visible, nor were the edge of waste markers that had been installed in this area. 11. Inspection of the landfill was accomplished with the use of an all-terrain vehicle and on foot. The top of the landfill was observed and found to be very uneven, with little to no compaction of the waste. Waste material was very dry and dust clouds were produced as a result of the movement of the ATV and of the slight breeze that came up periodically during the inspection. 12. The fore bay and sediment pond are located on the north side of the landfill. Site drainage is accomplished by means of a ditch line that extends from the southern side of the fill area, along the east side of the landfill to the fore bay. At the time of this inspection, the fore bay was found to be dry and to contain sediment and some accumulated material from the landfill. The sediment pond was not entirely visible; however, the water level was well below the spillway located at the northwestern end. Sediment accumulation was evident on the spillway. It did not appear that any maintenance had been performed on the fore bay and sediment basin, as requested in the previous inspection report, dated 7/13/2018. 13. The fore bay is located near the toe of the landfill, and there appears to be no separation between the disposal area and the fore bay. Consequently, any liquid leaving the landfill would travel directly to the fore bay. 14. The eastern slopes of the landfill were found to be irregular and ungraded, with uncompacted waste. Mr. Hall explained the difficulty of constructing slopes with the ASR material, which does not compact well and is not uniform in size. The drainage ditch and the berm that separates it from the waste in the fill area were not readily identifiable. No clear edge of waste was discernable on the eastern side of the landfill. 15. Ensure that the waste boundary of the landfill is accurately located and delineated with permanent edge- of-waste markers that are easily visible and readily identifiable. 16. Mr. Winegar stated that stormwater that falls inside the disposal boundary remains in the landfill and is absorbed into the waste. He added that the ASR reacts in a manner similar to that of a sponge, so that water runoff leaving the landfill footprint is not an issue. A view of the southwest side of the landfill from the processing area. The western perimeter road and waste boundary markers are no longer visible. Note that the entire area appears to be ASR material. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 6 A view of the eastern slope of the landfill from the top. No waste boundary is identifiable in this area, and the drainage ditch and berm that protects it are no longer visible. A view of the northern slope of the landfill from the top. The landfill slope is under construction. This area is located directly adjacent to the fore bay. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 6 A view of the northern slope of the landfill from the toe of the slope. A view of the fore bay from the toe of the northern landfill slope. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 6 Please contact me if you have any questions or concerns regarding this inspection report. ________________________________________ Phone: 336-776-9672 Susan Heim Environmental Senior Specialist Regional Representative Sent on: June 22, 2017 to James Winegar. X Email Hand delivery US Mail Certified No. [ ] Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Deb Aja, Western District Supervisor - Solid Waste Section Christine Ritter, Hydrogeologist – Solid Waste Section Adam Ulishney, Environmental Compliance Branch Head – Solid Waste Section Ming-Tai Chao, Permitting Engineer – Solid Waste Section Sherri Stanley, Permitting Branch Head – Solid Waste Section Scott McDaniel, Regional Manager – OmniSource Southeast