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Home My WebLink About3406_CORR_20180720 WASTE MANAGEMENT Environmental Legacy Management Group 1850 Parkway Place Suite 600 Marietta, GA 30067 July 20, 2018 Ms. Susan Heim NC Department of Environmental Quality Division of Waste Management – Solid Waste Section 1646 Mail Service Center Raleigh, North Carolina 27699-1646 Via Email: susan.heim@ncdenr.gov RE: Response to NOD – Leachate Release Piedmont Landfill and Recycling Center, Kernersville, North Carolina Permit Number 34-06 Dear Ms. Heim: Waste Management offers the following response and status update to the Notice of Deficiency (NOD) dated July 13, 2018, related to the recent leachate release that occurred at the Piedmont Landfill. This letter will also serve as the certification you requested in the NOD, which was due within 10 days of the date of the NOD. In the NOD, you requested the following four action be taken. Following each action item in italics is a response and/or status update concerning that action. 1. Implement the Leachate Release Assessment Sampling Plan dated July 11, 2018 as approved by Christine Ritter, Hydrogeologist on July 12, 2018. The plan must be implemented within 7 days of Ms. Ritter’s approval with documentation detailed in Ms. Ritter’s email dated July 5, 2018 within 10 days after receipt of analytical results from the laboratory. As of July 17, 2018, all soil samples and surface water samples specified in the Sampling Plan had been collected and delivered to Test America for the required analyses. Upon receipt of the laboratory’s final analytical report, we will prepare and submit the results in a Sampling and Assessment Report within the required timeframe. 2. Submit a detailed written response to Ming-Tai Chao’s email dated July 6, 2018 regarding data to document status of the proper functioning of leachate collection system. The submittal shall provide leachate generation and disposal volumes data for each leachate pump from the date of the site closure to present. Attached to this letter is a table summarizing leachate disposal volumes from the Piedmont Landfill from 2005 to present. Data for the individual sumps is not available. Ms. Susan Heim July 20, 2018 Page 2 of 3 Also attached is a copy of the 1992 drawing showing the drain line from the old wash pad, which Ming requested. We believe that this drain line was capped and abandoned prior to construction of Phase 3 of the landfill. The damaged cleanout was on this drain line, not on the leachate force main; therefore, the released fluid may or may not have actually been leachate. 3. Submit a detailed written description, including waste disposal receipts, etc., of where any excavated soils have been stockpiled and their final disposition. The excavated soil was placed directly into covered roll-offs on site or stockpiled nearby until additional covered roll-offs can be provided. The stockpile was made by creating a circular berm of native soil and lining the area inside the berm with plastic. The stockpiled soil was placed on the plastic, and then covered with plastic until the excavation contractor can return with additional roll-offs to remove the stockpiled material. A composite sample of the excavated soil was collected for laboratory analysis and waste characterization. Upon receipt of the final laboratory report, the results will be sent to the Hanes Mill Road Landfill to serve as a special waste profile so the soil can be approved for disposal. Once approved, all of the excavated soil will be transported to the Hanes Mill Road Landfill for disposal. The soil disposal will be documented and the documentation will be included in the Sampling and Assessment Report. 4. Submit a detailed written description of any impacts to the adjacent Kernersville Landfill facility, located adjacent to the leachate cleanout along Freeman Road. A discussion of potential impacts from the release from the abandoned drain line cleanout on the adjoining Kernersville Landfill property will be included in the Sampling and Assessment Report based on the sampling results. Waste Management has completed the installation of bollards around all cleanouts on the abandoned drain line along Freeman Road. The bollards were installed to prevent any future damage that could result in another release. In addition, we have completed the installation of a second layer of security fencing in front of the leachate tank system. We have installed the second layer of fence to help hinder illegal dumping in the leachate loadout pad and help further secure the leachate tank system. Also, please note that I have moved into a new office location, and our group has changed its name. Our new group name and my new office address is: Waste Management Environmental Legacy Management Group 1850 Parkway Place Suite 600 Marietta, GA 30067 We will continue to keep you informed of our progress on this issue. If you any question or require additional information, please contact via email at alacsama@wm.com or through my cell phone at 404-354-3132. Van Burbach of Joyce Engineering is also available to assist you. Ms. Susan Heim July 20, 2018 Page 3 of 3 Sincerely, Waste Management of Carolinas, Inc. Alexander Lacsamana, P.E. District Manager Waste Management Environmental Legacy Management Group Attachments: Piedmont Landfill Monthly Leachate Disposal (January 2005- July 2018) Piedmont Landfill- 1992 Drawing Showing Location of the Abandoned Drain Line. cc: Van Burbach, Joyce Engineering Christine Ritter, Ming-Tai Chao, NCDEQ Monthly Annual Average Average Leachate Leachate per per Month-Year Volume Total Month Day (gallons) (gallons) (gallons) (gallons) Jan-05 169,143 Feb-05 57,198 Mar-05 152,755 Apr-05 114,733 May-05 30,222 Jun-05 24,694 Jul-05 53,310 Aug-05 303,770 Sep-05 68,019 Oct-05 60,923 Nov-05 60,013 Dec-05 164,974 1,259,754 104,980 3,451 Jan-06 178,318 Feb-06 212,068 Mar-06 87,073 Apr-06 56,014 May-06 63,861 Jun-06 77,265 Jul-06 127,375 Aug-06 28,860 Sep-06 91,645 Oct-06 69,278 Nov-06 87,995 Dec-06 68,163 1,147,915 95,660 3,145 Jan-07 151,960 Feb-07 93,840 Mar-07 211,714 Apr-07 138,277 May-07 93,971 Jun-07 95,333 Jul-07 61,167 Aug-07 33,309 Sep-07 29,247 Oct-07 33,649 Nov-07 61,178 Dec-07 75,851 1,079,496 89,958 2,958 Piedmont Landfill Monthly Summary of Leachate Volume Disposed Waste Managment - Piedmont Landfill Permit # 34-06 1 of 5 Joyce Engineering 7/19/2018 Monthly Annual Average Average Leachate Leachate per per Month-Year Volume Total Month Day (gallons) (gallons) (gallons) (gallons) Piedmont Landfill Monthly Summary of Leachate Volume Disposed Jan-08 95,293 Feb-08 264,203 Mar-08 241,022 Apr-08 230,013 May-08 130,840 Jun-08 58,837 Jul-08 17,962 Aug-08 51,358 Sep-08 37,336 Oct-08 77,698 Nov-08 44,147 Dec-08 179,242 1,427,951 118,996 3,912 Jan-09 141,138 Feb-09 146,571 Mar-09 261,078 Apr-09 146,967 May-09 36,397 Jun-09 32,226 Jul-09 32,233 Aug-09 32,090 Sep-09 32,231 Oct-09 36,422 Nov-09 67,268 Dec-09 61,594 1,026,215 85,518 2,812 Jan-10 44,704 Feb-10 69,824 Mar-10 259,516 Apr-10 187,039 May-10 53,595 Jun-10 49,903 Jul-10 38,159 Aug-10 50,845 Sep-10 44,932 Oct-10 0 Nov-10 0 Dec-10 11,933 810,450 67,538 2,220 Waste Managment - Piedmont Landfill Permit # 34-06 2 of 5 Joyce Engineering 7/19/2018 Monthly Annual Average Average Leachate Leachate per per Month-Year Volume Total Month Day (gallons) (gallons) (gallons) (gallons) Piedmont Landfill Monthly Summary of Leachate Volume Disposed Jan-11 50,682 Feb-11 69,019 Mar-11 83,860 Apr-11 24,841 May-11 87,954 Jun-11 57,180 Jul-11 12,798 Aug-11 43,532 Sep-11 8,728 Oct-11 60,795 Nov-11 24,782 Dec-11 37,015 561,186 46,766 1,537 Jan-12 79,704 Feb-12 179,416 Mar-12 80,634 Apr-12 75,133 May-12 30,840 Jun-12 32,091 Jul-12 12,435 Aug-12 31,323 Sep-12 86,526 Oct-12 38,017 Nov-12 53,577 Dec-12 55,043 754,739 62,895 2,068 Jan-13 38,239 Feb-13 69,206 Mar-13 44,137 Apr-13 43,834 May-13 55,036 Jun-13 44,569 Jul-13 19,461 Aug-13 36,735 Sep-13 0 Oct-13 85,209 Nov-13 43,200 Dec-13 48,752 528,378 44,032 1,448 Waste Managment - Piedmont Landfill Permit # 34-06 3 of 5 Joyce Engineering 7/19/2018 Monthly Annual Average Average Leachate Leachate per per Month-Year Volume Total Month Day (gallons) (gallons) (gallons) (gallons) Piedmont Landfill Monthly Summary of Leachate Volume Disposed Jan-14 32,148 Feb-14 32,204 Mar-14 48,275 Apr-14 55,524 May-14 11,270 Jun-14 12,072 Jul-14 117,575 Aug-14 17,621 Sep-14 18,149 Oct-14 24,606 Nov-14 17,642 Dec-14 35,556 422,642 35,220 1,158 Jan-15 25,255 Feb-15 12,180 Mar-15 37,990 Apr-15 23,246 May-15 13,386 Jun-15 83,567 Jul-15 25,259 Aug-15 35,575 Sep-15 22,369 Oct-15 33,728 Nov-15 29,533 Dec-15 52,545 394,633 32,886 1,081 Jan-16 41,041 Feb-16 42,463 Mar-16 55,154 Apr-16 18,460 May-16 42,214 Jun-16 17,848 Jul-16 24,664 Aug-16 68,851 Sep-16 45,633 Oct-16 30,925 Nov-16 25,912 Dec-16 67,783 480,948 40,079 1,318 Waste Managment - Piedmont Landfill Permit # 34-06 4 of 5 Joyce Engineering 7/19/2018 Monthly Annual Average Average Leachate Leachate per per Month-Year Volume Total Month Day (gallons) (gallons) (gallons) (gallons) Piedmont Landfill Monthly Summary of Leachate Volume Disposed Jan-17 57,407 Feb-17 58,020 Mar-17 68,921 Apr-17 60,458 May-17 81,224 Jun-17 81,779 Jul-17 54,784 Aug-17 171,066 Sep-17 48,894 Oct-17 42,240 Nov-17 12,355 Dec-17 6,299 743,447 61,954 2,037 Jan-18 18,531 Feb-18 23,382 Mar-18 19,095 Apr-18 68,582 May-18 12,150 Jun-18 23,936 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 165,676 27,613 153 Waste Managment - Piedmont Landfill Permit # 34-06 5 of 5 Joyce Engineering 7/19/2018