1403_INSP_20180627

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 1 of 5
UNIT TYPE:
Lined
MSWLF X LCID YW Transfer Compost SLAS COUNTY: Caldwell
Closed
MSWLF HHW White
goods X Incin T&P X FIRM PERMIT NO.: 14-03
CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE
Date of Site Inspection: June 27, 2018 Date of Last Inspection: June 14, 2017
FACILITY NAME AND ADDRESS:
Foothills Environmental Landfill
2800 Cheraw Road
Lenoir, North Carolina 28645
GPS COORDINATES: N: 35.91531 W: 81.59568
FACILITY CONTACT NAME AND PHONE NUMBER:
Owner: Caldwell County
Contact: Stan Kiser, County Manager
Telephone: [phone]
Email address: [e-mail]
Operator: Republic Services of North Carolina, LLC d.b.a. Foothills Regional Landfill
Contact: Roger Watts, Division Manager, Foothills Regional Landfill
Telephone: [phone]
Email Address: [e-mail]
FACILITY CONTACT ADDRESS:
Stan Kiser, Caldwell County Manager
Post Office Box 2200
Lenoir, North Carolina 28645
CT Corporation System, Registered Agent
Republic Services of North Carolina, LLC d.b.a. Foothills Regional Landfill
150 Fayetteville Street, Box 1011
Raleigh, North Carolina 27601
PARTICIPANTS:
Roger Watts, Division Manager – Republic Services of NC, LLC
Jason Reynolds, Operations Supervisor – Republic Services of NC, LLC
Derek Bouchard, Environmental Engineer – Republic Services of NC, LLC
Charles Gerstell, NCDEQ – Solid Waste Section
STATUS OF PERMIT:
A Permit to Construct 1403-MSWLF-1998, Foothills Environmental Landfill Phase 4 – Cell 5B and Permit to Operate
1403-MSWLF-1998, Foothills Environmental Landfill Phases 1, 2, 3, and 4 – Cell 5A was issued to Caldwell County
(Owner) and Republic Services of North Carolina, LLC, (Operator) a wholly owned subsidiary of Republic Services,
Inc., d.b.a Foothills Regional Landfill on October 10, 2016. The Permit to Operate shall expire on December 23, 2018.
PURPOSE OF SITE VISIT:
Comprehensive Inspection
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 5
STATUS OF PAST NOTED VIOLATIONS:
N/A
OBSERVED VIOLATIONS:
15A North Carolina Administrative Code 13B .1626(2)(a) states: “Except as provided in Sub-Item (b) of this Item, the
owners or operators of all MSWLF units must cover disposed solid waste with six inches of earthen material at the end of
each operating day, or at more frequent intervals if necessary, to control disease vectors, fires odors, blowing litter, and
scavenging.”
During the inspection exposed waste was observed exposed intermittently along the northern slope of Cell – 5A. Mr.
Watts explained that a contactor had excavated in this area to expose the liner of Cell – 5A in order to tie in the new liner
for Cell – 5B which is currently under construction. Mr. Watts further explained that the area was first excavated in early
May, and for a second time during the last week of May or first of June. Therefore, Republic Services of NC, LLC was in
violation of 15A NCAC 13B .1626(2)(a) in that waste was not covered at the end of the previous working day.
On June 28, 2018, Mr. Watts provided photo evidence showing that all waste within the area of concern had been properly
covered with earthen material. Therefore, this violation is resolved. Thank you for your cooperation in this matter.
View of exposed waste on north slope of Cell 5A on View of exposed waste on north slope of Cell 5A on
6/27/18 (photo by C. Gerstell) 6/27/18. (photo by C. Gerstell)
Photo of north slope of Cell 5A submitted by
Roger Watts via e-mail on 6/28/18.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 5
ADDITIONAL COMMENTS
1. The facility consists of a lined MSWLF, Tire Management Area, White Goods Area, and Mulching and Grinding
Area.
2. The facility had proper signage.
3. A gate was located at the entrance to the facility to prevent unauthorized access.
Records Review:
4. The facility is permitted to accept up to 1,250-tons of waste per day. Tonnage records for May 2017 through May
2018 were verified. The facility received approximately 1,238-tons of waste each operating day during this time.
5. Water quality monitoring was being performed semiannually as required. Reports for the 2nd semiannual sampling
event for 2017 (performed on July 27, 2017) and the 1st semiannual sampling event for 2017 (performed on
January 29-30, 2018) were verified.
6. Leachate sampling was being performed semiannually as required and waste performed concurrently with water
quality monitoring.
7. Methane monitoring was being performed quarterly as required. Reports for monitoring events performed on
6/28/17, 9/1/17, 11/27/17, 3/14/18, and 5/23/18 were verified. Methane was recorded above the lower explosive
limit on multiple occasions:
x 9/1/17: 16.7% by volume
x 11/27/17: 22.2% and 22.3% by volume
x 3/14/18: 35.3% and 35.0% by volume
x 5/23/18: 41.8% by volume
Upon request, on July 7, 2018, Mr. Bouchard submitted information describing the suspected cause of the methane
levels at GP-1 and a proposed plan to address the methane levels. Mr. Bouchard explained that the probe detection
correlates with the groundwater well next to it having VOC detections above groundwater protection standards
(GPS). He further explained that an Alternative Source Demonstration (ASD) has been submitted to Jackie
Drummond and the facility is in Appendix II monitoring currently. Mr. Bouchard explained in his correspondence
the plan as of right now:

1. Appendix II monitoring on all wells, likely will propose moving Appendix II monitoring to the well in
question and two upgrade/two downgrade in 2019.
2. Additional dewatering pumps have been installed in three gas extraction wells in Cell 1A, the front slope
closest to the groundwater monitoring well and gas probe. Those have been in and running since the week
before the site inspection.
3. A mitigation trench is scheduled to be installed in August along the toe of cell 1A that will cut off the
potential for gas migration in this direction. This will consist of an approximately 8’ deep trench with
clean stone and horizontal collector piping, paired with vertical collector connections to apply negative
vacuum. A low side sump will exist for dewatering, if needed.

Please continue efforts to evaluate methane levels at GP-1 and notify the Solid Waste Section as to the
effectiveness of proposed remedies. Information should be submitted to Ms. Jaclynne Drummond, Compliance
Hydrogeologist.
8. Random Load Inspection Forms were verified for January 2018 to present. The forms appeared to be in order.
9.
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 4 of 5
10. Leachate hauling records were verified for January – May 2017. A total of 3,011,009-gallons of leachate were
hauled from the facility during this time.
11. Scrap Tire Certification forms were observed and appeared to be properly completed.
12. Manager of Landfill Operations Certifications
x Jason Reynolds (expires 6/6/20)
x Roger Watts (expires 6/26/18. Recently renewed)
13. Certified Landfill Operation Specialist Certifications:
x Andrew Keen (expires 11/6/18)
x Mitcheal Ogle (expires 9/8/20)
x Mathew Pritchard (expires 3/30/19)
x Mark L. Spencer (expires 4/15/20)
x Richard Wilson (expires 9/8/20)
14. Asbestos disposal records were observed. The facility maintains a copy of waste manifests for each load of
asbestos waste received at the facility. An aerial image is placed in the record marking the general location of the
disposal location for each load of asbestos, and GPS coordinates are also recorded.
Operations Inspection of the MSWLF Unit:
15. Waste was being placed in Cell 5A at the time of inspection.
16. One waste tipper was in use.
17. No unacceptable waste steams were observed.
18. Multiple mobile wind fences had been purchased since the last inspection and were in use. Please ensure that any
waste collected by these devices is collected at the end of each operating day and returned to the working face.
19. The facility is approved for the use of petroleum contaminated soils (PCS), tarps, Posi-Shell, and auto shredder
residue (ASR) as alternative daily cover (ACM).
x Only Posi-Shell was being used as ACM at the time of inspection.
20. The facility was previously approved for the use of a leachate evaporation system within two zones of the landfill.
Republic Services of NC, LLC notified the Solid Waste Section on August 28, 2017 that the facility will not
operate the leachate evaporation system at the Foothills Regional Landfill, and the Operations Plan will be
modified during the next revision to reflect this change.
21. Leachate recirculation is approved within Phase 1, Cell 1 only. However, leachate is not recirculated at this time.
22. Facility staff were in the process of repairing eroded slopes on Cells 3A and 3C at the time of inspection.
Accumulated sediment was also being removed from roadside ditches along the west side of the landfill. Please be
sure to stabilize any slope repairs and ditches with a groundcover sufficient to restrain erosion.

Inspection of the Tire Collection Area:
23. Tires were being collected into multiple covered trailers west of the scalehouse and adjacent to the methane flare.
24. All tires were located within the designated trailers at the time of inspection.
25. This area was well managed.
Inspection of the White Goods Collection Area:
26. White goods containing chlorofluorocarbons (CFCs) are collected on a concrete pad west of the scalehouse
adjacent to the scrap metal collection area.
27. CFCs are removed by a contractor when metal is removed from the facility.
28. Multiple refrigerators were observed lying on their sides at the time of inspection. Some were located in the metal
pile, and had not yet been relocated to the designated area for white goods collection. Please ensure that all white
goods are stored in an upright condition to maintain the integrity of the device prior to removal of CFCs.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 5
Inspection of the Grinding Area:
29. This area is located within the landfill west of the current active cell.
30. The area consisted of a stockpile of land clearing debris and wooden pallets.
31. No concerns were observed with this area.
Supporting Comments:
32. Leachate tanks were observed.
x At the time of inspection, the tank read 3 ½-feet and 20 ½-feet.
x A concrete containment area is provided adjacent to the tans for use during pumping operations. The
containment area contains a sump located in the center with no outlet. The containment area has an
approximate capacity of 5,500-gallons of liquid.
x The tanks appeared to be well managed.
33. All roads within the facility were of all-weather construction and well maintained.
34. Sediment basins appeared to be maintained. Mr. Watts explained that accumulated sediment would be removed
from Wet Detention Basin #3 in the near future.
35. Site conditions were extremely wet as the result of multiple storms received at the facility during the previous two
days prior to the inspection.
Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone]
Charles T. Gerstell
Environmental Senior Specialist
Regional Representative
Sent on: 7/6/18 X Email Hand delivery US Mail Certified No. [ _]
Copies: Deb Aja, Western District Supervisor - Solid Waste Section
Digitally signed by Charles T. Gerstell
DN: cn=Charles T. Gerstell, o=Divsion of Waste
Management, ou=Solid Waste Section,
email=[e-mail], c=US
Date: 2018.07.06 14:09:13 -04'00'