3406_INSP_20180807

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: Forsyth
Closed
MSWLF X HHW White
goods Incin T&P FIRM PERMIT NO.: 3406
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: August 7, 2018 Date of Last Inspection: March 15, 2017

FACILITY NAME AND ADDRESS:
Piedmont Sanitary Landfill – Closed
9901 Freeman Road
Kernersville, NC 27284

GPS COORDINATES: N: 36.195582 ° W: -80.037215 °

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Alexander Lacsamana, District Manager, Environmental Legacy Management Group – Waste Management, Inc.
Telephone: [phone] (office); [phone] (mobile).
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
1850 Parkway Place, Suite 600
Marietta, GA 30339

PARTICIPANTS:
Alexander Lacsamana, District Manager, Environmental Legacy Management Group – Waste Management, Inc.
Van Burbach, Senior Technical Consultant – Joyce Engineering, Inc.
Jason Watkins, Field Operations Branch Head – Solid Waste Section
Christine Ritter, Hydrogeologist – Solid Waste Section
Ming-Tai Chao, Permitting Engineer – Solid Waste Section
Susan Heim, Environmental Senior Specialist – Solid Waste Section

STATUS OF PERMIT:
Closed MSW Landfill

PURPOSE OF SITE VISIT:
Partial Inspection

STATUS OF PAST NOTED VIOLATIONS:

1. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1604(b)(2)(L)(iii) states, “The permittee shall
report orally within 24 hours from the time the permittee becomes aware of the circumstances of any release or
discharge outside the liner, collection system or other containment component, any fire, or explosion from the
permitted landfill facility. Such reports shall be made to the Division representative at the appropriate regional
office of the Department of Environment and Natural Resources.”

A Notice of Deficiency was issued to Waste Management, Inc. on July 13, 2018 for failure to orally notify Susan
Heim, the Division representative at the Winston-Salem Regional Office, within 24 hours of becoming aware of a
leachate release on June 22, 2018. The notice imposed the following corrective actions:

1. Implement the Leachate Release Assessment Sampling Plan dated July 11, 2018 as approved by Christine
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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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.
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.
3. Submit a detailed written description, including waste disposal receipts, etc., of where any excavated soils
have been stockpiled and their final disposition.
4. Submit a detailed written description of any impacts to the adjacent Kernersville Landfill facility, located
adjacent to the leachate cleanout along Freeman Road.

Mr. Burbach stated that the soil sampling had been completed and that he had just received the laboratory analysis
that would be included in the Waste Management response. Based on this inspection, Waste Management shall
also investigate the status of the abandoned drain line, of which the damaged clean-out is a part, including
whether the line is connected to the facility’s leachate collection system.

OBSERVED VIOLATIONS:
No new violations were observed.

ADDITIONAL COMMENTS

1. This inspection and meeting took place at the request of Mr. Lacsamana to discuss the leachate release which
occurred on June 22, 2018 at a clean-out located on the south side of Freeman Road just east of the leachate
storage tanks.
2. A short tour of the closed landfill unit served to familiarize Ms. Ritter and Mr. Chao with the site.
3. The landfill cap was observed to have a well-established vegetative cover, comprised of a mixture of native
grasses and lespedeza. Although Mr. Lacsamana stated that the cap had been mowed within the past few weeks,
the vegetation had grown to waist height.
4. One area of the landfill cap, located near the center of the top, had been of concern at the time of a previous
inspection on January 31, 2017. At that time, part of the slope had failed, and it had appeared that efforts to
repair it with matting had been ineffective. During the current inspection, Mr. Lacsamana pointed out that the
area had been repaired, regraded and reseeded. He also noted the white stakes that had been used to cordon the
area off so that mowing tractors would not damage the newly established vegetation.
5. Several of the groundwater monitoring wells were observed from the vehicle and appeared to be well-
maintained and accessible, with proper construction and labeling in place.
6. The area of the leachate release was observed. Two covered roll-off containers were located near the damaged
clean-out. Mr. Lacsamana stated that these containers held some of the contaminated soil that had resulted from
the incident. A pile of tarped soil was located in the same vicinity. Mr. Lacsamana explained that, since no other
containers had been available, clean soil had been used to create a berm which had then been lined with plastic;
the additional contaminated soil had been placed within this containment and covered with plastic to prevent
production of additional leachate.
7. The clean-out itself was found to have been reduced to ground level and sealed. Two concrete bollards had been
set, one on either side of the clean-out, to eliminate the potential for future damage. Mr. Lacsamana stated that
he and Mr. Burbach felt the clean-out was part of an old drain line that had been capped and abandoned as the
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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active landfill had expanded. Mr. Watkins asked if there were records supporting this assumption and Mr.
Burbach stated that they had not been able to locate drawings or reports that could corroborate this opinion. Mr.
Burbach was able to produce a drawing that showed a portion of the line as it extended from the Phase I area of
the landfill to what is now the south side of Freeman Road and then west to the leachate tanks. Some discussion
ensued concerning the need to investigate the line and determine whether or not it was still connected to the
leachate collection system. Mr. Watkins stated that it would be advisable for Waste Management to ensure that
the line was not capable of receiving leachate from the tanks should a problem in the system cause leachate to
back up into the abandoned line. Mr. Lacsamana agreed to provide information about the status of the
abandoned drain line along with the laboratory analysis of the soil samples taken from the area surrounding the
damaged clean-out, and the final disposition of the excavated soils.
8. The leachate tank area was observed next, and Mr. Lacsamana pointed out the new fence that now encloses the
access driveway to the leachate tanks. Previously, the tank secondary containment had been secured by a chain
link fence with a locking gate. Mr. Lacsamana stated that there had been problems with illegal dumping at the
site, so a second fence had been installed, with locking gates at both ends of the horseshoe access roadway. The
five leachate storage tanks were visible, but a close inspection was thwarted by the chest-high weeds that had
grown up around the containment wall. Mr. Lacsamana stated that the tank area is maintained on a schedule
along with the landfill cap.

A view of the area surrounding the damaged clean-out. One of the roll-off containers that is being used to
store excavated soils can be seen in the background, along with the white protective bollards that were
installed on either side of the sealed clean-out. Additional excavated soil, stored in a lined berm, can be seen
tarped in the foreground. (Photo taken by S. Heim 8/6/18.)
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.

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

Sent on: August 10, 2018 to Al
Lacsamana, Waste
Management, Inc.
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
Ming-Tai Chao, Permitting Engineer – Solid Waste Section
Van Burbach, Senior Technical Consultant – Joyce Engineering, Inc.