1910_Brickhaven_INSP_20190131

FACILITY COMPLIANCE INSPECTION REPORT
Department of Environmental Quality
Division of Waste Management - Solid Waste Section

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Chatham
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 1910-STRUC-2015
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: January 31, 2019 Date of Last Inspection: August 24, 2018

FACILITY NAME AND ADDRESS:
Brickhaven No. 2
1473 Moncure-Flatwood Road
Moncure, NC

GPS COORDINATES: N: 35.596 W: -79.010

FACILITY CONTACT NAME AND PHONE NUMBER:
Thomas (Tom) Flannagan, Project Director, Direct: 704-985-2992, [e-mail]

FACILITY CONTACT ADDRESS:
Green Meadow, LLC
352 Brickyard Road
Sanford, NC 27330
[phone]

PARTICIPANTS:
Shawn McKee, NCDEQ, Solid Waste Section
Ben Jackson, NCDEQ, Solid Waste Section
David Giachini, NCDEQ, Solid Waste Section
Tom Flannagan, Charah, Inc.

STATUS OF PERMIT:
Permit to Construct and Operate issued June 5, 2015
This permit shall expire June 5, 2025

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 4

ADDITIONAL COMMENTS
The site is a lined coal combustion products structural fill permitted for mine reclamation in conjunction
with NCDEQ DEMLR Mine Permit 19-25.

1. The structural fill permit, site plan, and operations plan were discussed during the inspection. The
Permit to Construct and Operate was issued on June 5, 2015 and approves the operation of Cells 1
through Cell 5. Permit Approval to Operate Cell 6C was issued January 9, 2019. The permit is
subject to review by June 5, 2020.

2. According to the approved site operations plan, operations can occur 24 hours a day, 7 days per
week. Solid Waste Section approval is needed if there is a change in operating hours. A sign
providing the facility name, permit number, operating hours, and emergency contact numbers is
posted at the site entrance.

3. The structural fill began placing coal combustion products on October 23, 2015. At the time of the
inspection, trains were operating as normal but excavation activities at the Duke Energy Riverbend
Steam Station were nearing completion. Each train has around 85 cars and has the capacity to
transport 8,500 to 8,800 tons of CCPs. Ash is conditioned to 18-20% moisture content prior to
transport. At the time of the inspection, ash was being placed in cells 6C.

Active ash placement area - Cell 6C. Berms control leachate run-off.

4. The structural fill has an approved dust control plan. Water trucks are utilized to control road dust,
as needed. Water trucks were not operating at the time of the inspection because the air
temperature was 25 degrees Fahrenheit which is too cold to operate water trucks. During these
conditions, truck speeds are reduced to limit dust. Operations will be suspended if necessary. No
significant windblown dust from operations or roadways was noted during the inspection.

5. Annually by August 1, the Permittee must submit an annual facility report to the Section. During
the time period between July 1, 2017 and June 30, 2018, the facility reported that 2,086,172.9 tons
of ash were placed in the structural fill. Between 2015 and the end of 2018, a total of 7,033,089.33
tons were placed in the structural fill; 1,993,697.70 tons came from Sutton and 5,013,091.54 tons
from Riverbend.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 4

6. A readily accessible unobstructed path shall be cleared and maintained so that four-wheel drive
vehicles may access monitoring locations, at all times. Groundwater monitoring wells are well
marked and protected from vehicular traffic by yellow bollards and flags. All groundwater
monitoring wells must be secured with locks and have permanent well tags. Monitoring wells
observed during the inspection were being properly maintained.

7. Roadways are of all-weather construction. Where practicable, roadways are one-way to reduce
vehicular conflicts. A wheel washing station has been installed to reduce migration of coal
combustion products from truck traffic.

8. Three 500,000 gallon tanks have been installed onsite to hold leachate prior to offsite treatment. The
leachate tanks were observed during the inspection. Tank levels are checked by onsite staff on a
daily basis. An average of 94,000 to 98,000 gallons a day currently are pumped from the tanks and
trucked to wastewater treatment plants permitted to accepted the leachate. Leachate is taken offsite
for treatment or used within the footprint of the lined cells for dust control.

9. Storm water from the rail unloading yard is sloped to drain into an approximately 400,000-gallon
underground storage tank. The tank has the capacity to hold the run-off from a 25 year/24 hour
storm event. This water can be used for dust control on the lined area of the structural fill.

10. Cells that have reached final grade have been capped with 40 mil LLDPE geomembrane,
geocomposite, four feet of cover soil on the side slopes and a minimum of two feet of cover soil on
the top deck meeting the approved specifications, and installation of the perimeter and cap drainage
systems. Erosion rills have been repaired on the northeastern facing slope and vegetation is
becoming established.
Northeastern side slope – photo-8/24/18 photo-1/31/19

Please contact me if you have any questions or concerns regarding this inspection report.
Phone: [phone]
Environmental Senior Specialist
Regional Representative
Sent on:
March 7, 2019
Email:
X
Hand delivery US Mail Certified No. [ _]
Copies: Ed Mussler, Section Chief, Solid Waste Section
Jason Watkins, Field Operations Branch Head, Solid Waste Section
Elizabeth Werner, Permitting Hydrogeologist, Solid Waste Section
Ben Jackson, Permitting Engineer, Solid Waste Section