2906_INSP_20181019

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 11

UNIT TYPE:
Lined
MSWLF X LCID YW Transfer X SLAS COUNTY: Davidson
Closed
MSWLF X HHW X White
goods X Incin T&P FIRM PERMIT NO.: 2906
CDLF X Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: October 19, 2018 Date of Last Inspection: October 4, 2018

FACILITY NAME AND ADDRESS:
Davidson County Integrated Solid Waste Management Facility
220 Davidson County Landfill Road
Lexington, NC 27292

GPS COORDINATES: N: 35.85281° W: 80.17620°

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Charlie Brushwood
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
P. O. Box 1067
Lexington, NC 27293-1067

PARTICIPANTS:
Charlie Brushwood – Davidson County
Steven Sink – Davidson County
Angela Jones – Davidson County
Lynn Rineer – Davidson County
Lee Hill, Environmental Senior Specialist – Solid Waste Section
Susan Heim, Environmental Senior Specialist – Solid Waste Section

STATUS OF PERMIT:
2906-MSWLF-1994: Closed
2906-MSWLF-2008: Life of Site Permit Issued 03/12/2018
2906-TRANSFER-2013: Life of Site Permit Issued 03/12/2018
2906-HHW: Issued 03/12/2018; Expires 05/28/2023

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
None

OBSERVED VIOLATIONS:

1. RESOLVED: 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s)
shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the
permit.” Permit to Operate No. 2906, Attachment 1, General Permit Conditions/Information, Part I, Item 6 states,
“Operation of this solid waste management facility must be in accordance with the Solid Waste Management
Rules, 15A NCAC 13B, Article 9 of the Chapter 130A of the North Carolina General Statutes, the conditions
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 11

contained in this permit, and the approved plan.” Permit to Operate No. 2906, Attachment 1, General Permit
Conditions/Information, Part I, Item 7 states, “This permit is issued based on the documents submitted in support
of the application for permitting the facility including those identified in the “List of Documents for the Approved
Plan” which constitute the approved plan for the facility.” Permit to Operate No. 2906, Attachment 1, General
Permit Conditions/Information, Part VI, lists DIN 28787 – Permit to Construct Application, Davidson County
MSW Landfill – Phase 2, Area 3, Prepared by S+G September 2017 and revised through March 2018 as one of
the documents for the Approved Plan. Section 2.3.1, Waste Receiving and Inspection, of the Operations Manual
(March 2018) - Attachment E of Permit to Construct Application – states, “Vehicles are randomly selected for
screening on a regular basis, depending on personnel available. At least two vehicles per week entering the MSW
landfill and one vehicle per week entering the transfer station, but not less than 1% based on number of loads
entering the landfill or transfer station (based on the previous week’s total) will be randomly selected by
inspection personnel.”

During this inspection, Davidson County was observed to be in violation of 15A NCAC 13B .0203(d) for
failing to perform and/or document the required waste screening provisions stated in the approved
Operations Manual (Revised March 2018). Facility staff stated that 2 random waste screenings are
conducted weekly at the facility, and a review of the records confirmed that this was the case. Facility staff
also stated that between 80 and 100 loads are received at the active MSW landfill during each weekday of
operation. This would require a minimum of 1 waste screening per operating day. After assessing the
requirements, facility staff immediately implemented a change in procedure to perform the random
inspection at least 6 loads per week at the MSW landfill. Therefore, this violation is considered to be
resolved.

2. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s) shall be
considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.”
Permit to Operate No. 2906, Attachment 1, General Permit Conditions/Information, Part I, Item 6 states,
“Operation of this solid waste management facility must be in accordance with the Solid Waste Management
Rules, 15A NCAC 13B, Article 9 of the Chapter 130A of the North Carolina General Statutes, the conditions
contained in this permit, and the approved plan.” Permit to Operate No. 2906, Attachment 1, General Permit
Conditions/Information, Part I, Item 7 states, “This permit is issued based on the documents submitted in support
of the application for permitting the facility including those identified in the “List of Documents for the Approved
Plan” which constitute the approved plan for the facility.” Permit to Operate No. 2906, Attachment 1, General
Permit Conditions/Information, Part VI, lists DIN 28787 – Permit to Construct Application, Davidson County
MSW Landfill – Phase 2, Area 3, Prepared by S+G September 2017 and revised through March 2018 as one of
the documents for the Approved Plan. Section 1.12 – Record Keeping Program, of the Operations Manual (March
2018) - Attachment E of Permit to Construct Application – lists all records that will be maintained in an operating
record at the facility.

Davidson County is in violation of 15A NCAC 13B .0203(d) for failing to maintain all required records at
the facility, including but not limited to the following: leachate records; employee training procedures and
records of training completed; semi-annual operations training and testing; financial assurance
documentation.

To achieve compliance, Davidson County must maintain all records in an operating record at the facility, as listed
in Section 1.12 – Record Keeping Program – of the approved Operations Manual (March 2018). An additional
inspection will be performed to confirm that compliance has been achieved.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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ADDITIONAL COMMENTS
1. All photos included in this inspection report were taken by Susan Heim on October 19, 2018.
Records Review:
2. The current Permit to Operate and approved Operations Manual were available at the Phase 2 scale house for
review.
3. Tonnage records were provided for both the MSW landfill and the transfer station for the current fiscal year to
date.
4. The following tonnage data was noted for the MSW landfill unit:
 13,417.58 tons of waste were accepted in July 2018;
 13,678.57 tons of waste were accepted in August 2018;
 12,799.78 tons of waste were accepted in September 2018;
 8,008.02 tons of waste were accepted to date in October 2018.
5. The following tonnage data was noted for the transfer station:
 185.72 tons of waste were accepted in August 2018;
 203.65 tons of waste were accepted in September 2018;
 57.70 tons of waste were accepted to date in October 2018.
6. The facility has a discharge permit to pump and haul leachate to the City of Lexington’s waste water treatment
plant from both Phase 1 leachate pond and the Phase 2 leachate tank. However, during late spring, the City
announced major maintenance at the plant and cut Davidson County’s leachate disposal down to a maximum of
3 loads per day. Decisions by the previous Public Services Director had cut the frequency of leachate disposal,
the system already had a lot of stored leachate when the City’s reduction in service took effect. Several heavy
rain events during the summer months necessitated drawing down the levels of both the pond and the tank in
advance of Hurricane Florence (9/16/18). Mr. Brushwood stated that the county had contracted Shamrock
Environmental to pump and haul leachate. He added that he had also negotiated with the City to expand the
amount of leachate accepted at the waste water treatment plant as much as possible. In addition, Mr. Brushwood
explained that he had been given permission by the Solid Waste Section Chief to spray leachate onto the top of
the landfill as an emergency remedy prior to the storm.
7. Leachate pump and haul records available at the facility only accounted for loads taken for disposal during the
months of March, May and September. A scanned copy of monthly logs was submitted via email following the
inspection. After reviewing the information provided, it was determined to be incomplete. Ensure that a
complete record of leachate generation is maintained at the facility and is available for review upon
request. (See Observed Violations section of this report for additional information.)
8. Leachate collection system inspection records were reviewed for the period January through October 2018. No
issues with the tank or collection system integrity were noted. The annual safety drill, designed to practice and
review emergency procedures for the leachate collection system, was conducted on August 8, 2018 by Mr.
Brushwood.
9. The county contracts annually for cleaning and maintenance of the leachate collection system. Mr. Sink stated
that arrangements were underway to have JetClean perform this annual maintenance in November. Records
indicated that the previous flushing and cleaning of leachate lines took place on November 28, 2017.
10. The cover log, where the type of cover used on the working face at the end of the day, weather conditions and
rain totals are recorded, was reviewed for the period December 2017 through October 2018. It appeared that
some entries for soil cover had been omitted from the log. Ensure that the cover log lists all information
pertaining to daily cover, including soil cover and alternative cover materials.
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 11

11. Random waste screening records from the transfer station were provided for the period September 16, 2016
through September 27, 2018. All forms appeared to have been filled out properly, and the inspection rate of one
load per week meets the Operations Manual stipulations.
12. Random waste screening records from the active landfill were provided for the period January through
September 2018. Again, all forms appeared to have been properly completed. Ms. Jones stated that the random
screenings at the landfill are conducted twice each week, as specified in the Operations Manual. She added that
the facility receives an average of 80 to 90 loads of waste per operating day. After reviewing the Operations
Manual and the tonnage reports, it was determined that at least one random waste screening would be conducted
during each operating week day. Ensure that a minimum of 1% of all incoming waste loads, at both the
active MSW landfill and transfer station, are randomly inspected, and that each inspection is recorded on
the proper form, placed in the facility operating record, and available for review upon request. (See
Observed Violations section of this report for additional information.)
13. A review of training records found that the following facility personnel have current SWANA certificates:
 Charlie Brushwood – Manager of Landfill Operations – expires 3/31/2019;
 William F. “Bill” Noonan – Transfer Station Operations Specialist – expires 3/23/2019;
 Steven Sink – Manager of Landfill Operations – expires 4/30/2020.
Mr. Brushwood stated that the former solid waste director had allowed operator certificates to lapse. He added
that 6 staff would be enrolled in the NCSWANA landfill operations specialist class on October 26, 2018.
Ensure that a certified operator is on duty at the MSW landfill and at the Transfer Station during all
operating hours for each facility.
14. Semi-annual groundwater monitoring records were made available via email following the inspection. The first
sampling event of 2018 took place March 12 – 16, 2018. On the Phase 1 side of the facility, 13 wells and 2
surface water locations were sampled for the closed, lined MSW landfill. In addition, 5 wells were sampled for
the closed C&D landfill. 12 monitoring wells, 2 surface water locations and 1 leachate point were sampled for
the active Phase 2 side of the facility. In all instances, no exceedances of organic constituents were noted.
Exceedances for several inorganic constituents were reported as being above the 2L level for both the closed
and active Phase 1 and Phase 2 facilities. However, these exceedances were evaluated in an historic context and
presumed to be naturally occurring rather than related to groundwater contamination by the landfill. The second
sampling event occurred in September 2018; however, the report for this event was not yet available for review.
15. Copies of the required quarterly landfill gas monitoring records for 2018 were also made available via email
following the inspection. A review of these logs confirmed that monitoring was taking place quarterly, as
required, and that 3 wells at the closed C&D landfill, 13 wells plus the scale house, maintenance building and
office at the closed MSW landfill, and 9 wells at the active MSW landfill were sampled. In all cases, 0%
methane by volume was reported.
16. Scrap tire certifications for the period July 1 through October 8, 2018. All forms appeared to have been
completed properly. Mr. Hill pointed out two tire generators – Todd’s Tire and BK Auto – that were using
photocopied signatures on their forms. Ms. Rineer stated that she would speak with these generators and ensure
that only original signatures are accepted in the future. Ensure that scrap tire certification forms are
completed properly, including original signatures by both the generator and the hauler, prior to
accepting tires for disposal.
17. Tire disposal is contracted through New River Tire. A review of tonnage records found that 176.95 tons of tires
were removed for disposal during August 2018; 78.11 tons were removed during September 2018; and, 74.38
tons had been removed so far in October 2018.
18. Electronics and television recycling and disposal are contracted through E-Cycle Secure, a registered, R2
certified vendor in North Carolina. Records for the period July 1 through October 18, 2018 indicated that a total
of three loads of e-waste had been collected, totaling 26.18 tons.
19. The facility is operated under NC General Storm Water Permit No. NCG120000.
20. Evacuation of CFCs from white goods is contracted through Rapid Recovery, Inc. A review of the records for
the white goods program indicated that, during the current fiscal year, a total of 17.86 tons of white goods had
been recycled to date.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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21. White goods and scrap metal are compacted by County staff and transported to a metal recycler for processing.
A review of tonnage reports indicated that 78.51 tons of scrap metal had been transported for recycling during
the first three months of the current fiscal year.
22. Ms. Jones stated that one mobile home had been received at the facility for deconstruction so far during the
current fiscal year.
23. Ms. Jones provided the record of asbestos waste received for the current fiscal year. The record indicated that
one load of asbestos containing material had been received from Davidson County Schools on July 3, 2018.
24. Mr. Sink stated that no waste determinations had been submitted during the current fiscal year.
25. HHW records are maintained in the locked office of the facility near the closed Phase 1 landfill. No key was
available during the inspection, so access to the onsite records was not possible. However, a summary of the
program for the current fiscal year was provided via email after the inspection. A review of these records
revealed the following:
 July 2018 - 10,540 lbs. of HHW were received from a total of 85 program participants;
 August 2018 – 7,864 lbs. of HHW were received from a total of 66 program participants;
 September 2018 – 5,750 lbs. of HHW were received from a total of 51 program participants.

Field Inspection

Leachate Collection System:
26. The leachate storage tank, located near the scale house on the Phase 2 side of the facility, was inspected and
found to be in good condition. The tank holds a maximum of 338,000 gallons and, according to the exterior
gauge, was currently less than half full. The secondary containment for the storage tank has a capacity of
490,000 gallons. Based on these conditions, the active landfill appeared to have ample capacity to handle
another large storm event, if necessary.
27. The leachate storage pond, located on the north side of the closed Phase 1 landfill was inspected and found to be
well-maintained and in good condition. The area surrounding the pond had been mown and was easily
accessible. Both aerators were in operation, and there was at least 3’ of freeboard visible in the pond.

Active MSW Landfill – Phase 2:
28. The cap of the Phase 2 landfill was inspected and found to be in relatively good condition in the aftermath of
Hurricane Florence (9/15/18) and Tropical Storm Michael (10/11/18).
29. Vegetative cover in the inactive areas appeared to be stable, and no evidence of erosion on these slopes was
evident.
30. Soil cover on the active portion of the landfill had been damaged by the heavy rains, and erosion rills were
visible in most areas. Mr. Brushwood stated that soil berms had been put into place prior to both storm events,
in an effort to limit damage to the slopes. He added that the ground was still soft and wet from additional
rainfall following the storms, so repairs had been slow going. However, preventive measures appeared to have
been effective since no waste had been exposed by erosion.
31. The new cell construction appeared to have weathered the storms. Slopes had washed in some areas and were in
need of repair. Some water had ponded on the bottom. Mr. Brushwood stated that the pump on hand proved too
small for the job, so a larger pump had been rented so that water could be removed from the cell as quickly as
possible.
32. A crew from the gas plant was working to install additional landfill gas wells on the north side of the landfill.
Equipment ruts and slope damage were visible in their area of operation, and some waste had been uncovered.
Ensure that slope repairs are made as installation work progresses in order to cover any waste that
becomes exposed and to avoid additional erosion and damage to the landfill slope.
33. The perimeter ditch appeared to be functioning; some sediment deposits were evident. Mr. Brushwood stated
that, as soon as the wet weather subsided, he planned to have landfill staff begin cleaning out the ditch.
34. The facility access roads are of all-weather construction and were observed to be in good condition. Mr.
Brushwood stated that he had made some repairs following the storms, and that he felt additional work was
needed.
35. A small working face was observed on the northeastern end of the landfill. No unacceptable waste was visible
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Division of Waste Management
Solid Waste Section

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in the working face.
36. The tipping area appeared to be of adequate size to permit equipment and vehicles to maneuver safely.
However, traffic flow in the area seemed to be problematic and somewhat confusing. The movement of trucks
entering and leaving the tipping area appeared to be in conflict with the movement of the compactor and loader.
Ensure that traffic flow in the operational area surrounding the working face is well thought out and
effective in providing easy access and safe maneuvering for both vehicles and landfill equipment.
37. Upon inspection, a significant amount of waste that had apparently been tracked up by the compactor was
visible in the operational area surrounding the working face. Mr. Brushwood stated that more equipment
breakdowns had occurred, and the landfill was currently being worked by an old county-owned loader and a
borrowed compactor. Ensure that the operational area is covered and tracked in with an adequate amount
of clean soil to avoid exposing waste during daily operations. It is also recommended that the loader be
used to push waste to the compactor so that the compactor can remain in the working face. This
procedure will limit damage to the cover and exposure of waste.
38. The top of the landfill was muddy and rutted from equipment use. Little vegetative cover was evident on the
inactive western portion. Mr. Brushwood stated that soil berms had held the intermediate soil cover in place on
the top of the landfill, but that repair work and seeding would be necessary when weather permits.
39. Windblown trash was found only on the eastern slope and appeared to be minimal. Mr. Brushwood stated that
his litter crew works over the entire facility daily, and that this area would be cleaned up within the next several
hours.
40. Mr. Brushwood pointed out the haul road for the new cell, stating his intention to construct an alternate haul
road that would circle to the south of the new cell. He explained that the original haul road will be a very short,
direct route from the scale house to the working face, whereas the alternate road could be used on wet days and
would help eliminate mud being tracked out of the facility onto the public road.
41. Permanent edge-of-waste markers were observed to be in place around the perimeter of the landfill, as required.

Closed MSW Landfill – Phase 1:
42. The closed landfill unit stopped accepting waste in November 2009 and began the 30-year post-closure
maintenance program on May 28, 2013.
43. Edge-of-waste markers were visible around the perimeter of the landfill.
44. The access roadway was of all-weather construction and was found to be well-maintained.
45. The landfill cap had been recently mowed and was observed to have a well-established vegetative cover, with
no erosion evident.
46. Drainage ditches appeared to be functioning properly, and no sediment accumulation was visible in the
perimeter ditch line.
47. Woody vegetation was evident along the slope ditches and in some spots in the perimeter ditch, where small
trees and brush had become established. Remove all trees and woody vegetation from the landfill cap and
ditch lines.

Transfer Station:
48. The transfer station building was not in use at the time of this inspection. The tipping floor and loading bay
were clean and no waste was present. Mr. Brushwood stated that the decision had been made to stop transfer
station operations for the time being, and to use the convenience area to accept small loads of waste instead. He
added that a decision about permanent closure would be made sometime in the near future.
49. Trench drains were clean and appeared to be functional. Mr. Brushwood confirmed that the leachate collection
tank is checked regularly and emptied as required.

HHW Collection Area:
50. The HHW program is operated through a contract with Resource Recovery and Reduction, Inc. (3RC), and is
permitted to accept materials only from Davidson County residents. County residents may also drop off HHW
at the 3RC facility in Winston-Salem (Permit # 34-15).
51. The collection area is located north of the transfer station building on the Phase 1 side of the facility.
52. The program is open to the public on the first Saturday of each month. 3RC staff operate the program, collect,
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Division of Waste Management
Solid Waste Section

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sort and package materials at the facility as they are collected.
53. A chain link fence surrounds the facility, and it is secured with locking gates to prevent unauthorized entry.
54. The facility is well organized, with specific areas for storage of various types of household waste, and was
observed to be clean and free from litter.
55. An office building is located on the north side of the main, covered unloading area. Mr. Brushwood stated that
monthly records and a tally of all waste stored at the site are maintained in the office. An office key was not on
hand during the inspection, so the records area was not inspected.
56. Latex paint had been palletized and shrink-wrapped in preparation for transport to the 3RC facility in Winston-
Salem. These pallets were stored under cover in the paint collection area on the southeast side of the facility.
57. The latex paint solidification tank, also located in the covered paint collection area, appeared to be
approximately 1/3 full of solidified paint.
58. Several plastic drums of non-regulated wastes were stored on a pallet under cover on the northwest side of the
main unloading area.
59. Plastic drums and gaylord boxes containing flammable waste were stored under the canopied area on the
southwest side of the facility.
60. Along the southern fence line to the east of the canopied storage area, sheds are installed to hold fluorescent
lamps, oil-based paints and paint products and other hazardous wastes. Mr. Brushwood did not have the keys to
these buildings, so they were not inspected internally. However, the sheds appeared to be clean, and no material
was observed to be leaking from them.
61. The emergency sump appeared to be dry and empty.
62. Some plastic film and trash was found just inside one of the gates on the south side of the facility, behind a roll-
off container. Ensure that all waste is removed from this area and placed into the roll-off container for
storage prior to proper disposal.

White Goods Collection Facility:
63. The white goods collection program area is located on the Phase 1 side of the Davidson County facility in the
recycling convenience area northwest of the scale house.
64. The facility was observed to be clean and well-maintained, with a small number of white goods stored on the
concrete collection pad. Mr. Brushwood stated that CFC removal and transport of white goods for recycling had
taken place recently.
65. White goods were separated so that units containing CFCs were properly staged in an upright condition in one
area, and non-CFC units were staged in another area.
66. A compactor is installed at the rear of the concrete collection area, and is used for baling white goods and scrap
metal for transport to a metal recycler. County staff operate the compactor and transport the metals as needed.

Scrap Tire Collection Area:
67. Scrap tires are collected in trailers provided by the county’s scrap tire recycler, New River Tire. Two trailers
were staged in the collection area, located just east of the scale house on the Phase 1 side of the facility.
68. Scrap tire certification forms are presented at the scale house, loads are visually screened by the scale house
operator, and customers are directed to the trailers where they are required to unload the tires and lace them into
the trailers.
69. The tire collection area was found to be clean and well-maintained.

Other Facility Operations:
70. The Phase 1 side of the Davidson County facility includes a convenience area for the drop-off of residential
recyclables, electronics and televisions, cardboard, textiles, used cooking oil, used motor oil and oil filters, lead
acid batteries, propane tanks and automobile radiators.
71. Electronics and televisions are accepted in a metal building located behind the transfer station. Inmates work to
separate and prepare materials for transport by the county’s electronics recycler, E-Cycle Secure. Televisions
and monitors are stacked, palletized, shrink-wrapped and stored awaiting transport. The area was clean and
well-organized; materials are processed and staged for transport as they are received.
72. A waste-to-energy plant is located on the southwest side of the closed Phase 1 MSW landfill. Davidson Gas
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Division of Waste Management
Solid Waste Section

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Producers LLC, operates and maintains the gas plant. The facility was observed to be clean and well-
maintained, and is surrounded by chain link fence which is secured by a locking gate to prevent unauthorized
access.

A view of the new cell construction from the southwest at the working face. Some erosion is visible on the side slopes,
and water has ponded from recent storm events. Storm preparations limited damage.
Churned up trash is evident on top of the active landfill in the operational area surrounding the working face.
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Division of Waste Management
Solid Waste Section

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The northern slope of the active landfill is damaged by landfill gas line installation. Equipment ruts and exposed waste
are visible throughout the area.
A view of the active landfill area, with the working face on top. Erosion rills are visible, but installation of soil berms
and other storm preparations limited the damage to the landfill slopes and the new cell construction below them. Note
the area to the right where slope repair has begun.
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Solid Waste Section

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The leachate collection
pond on the Phase 1 side
of the facility is well-
maintained with adequate
freeboard.
The electronics and television collection
area is clean and well organized.
The HHW collection area is well-designed and organized to
ensure safe, efficient collection events.
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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: October 29, 2018 to
Charlie Brushwood, Davidson
Co.
X Email Hand delivery US Mail Certified No. [ ]

Copies: Deb Aja, Western District Supervisor – Solid Waste Section
Lee Hill, Environmental Senior Specialist – Solid Waste Section
Steven Sink – Davidson County Integrated Solid Waste Management
Angela Jones – Davidson County Integrated Solid Waste Management