6401_NOCV_DEQ_RESP_20190416

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
Zee Lamb
Nash County Manager
120 W. Washington St.
Suite 3072
Nashville, NC 27856
NORTH CAROLINA
Environmental Quality
July 8, 2019
SUBJECT: Compliance Inspection Report —April 16, 2019
Nash County Landfill
Permit No. 6401-MSWLF-1983, 6401-CDLF-1999, 6403-CDLF-2000, DS64-006
Nash County, North Carolina
Dear Mr. Lamb,
The Solid Waste Section (Section) has reviewed the response letter, dated May 17, 2019,
submitted by Nash County, and the accompanying corrective action plan letter, dated May 16,
2019, prepared by Garrett & Moore, Inc. The following are the Section's response to the
County's outlined planned response actions to address issues noted in the April 16, 2019
compliance inspection report and proposed timeline for corrective actions:
Past Noted Violations
1. Closed MSWLF —Storm water seeps
Garrett & Moore believe the liquid observed at the surface of a recently graded area at
the east face of the closure landfill is likely impounded stormwater in a saturated
location seeping to the surface. However, any water that comes in contact with waste is
leachate and must be treated. Garrett & Moore have taken samples to determine if the
water released from the landfill is leachate. The laboratory analysis of those samples
will inform the corrective actions needed to resolve this violation. Please submit the
results to Ervin Lane.
As a temporary measure, until the testing results have determined the presence or
absence of leachate, the Section approves the method of adding soil in this area to
reestablish a suitable grade (percent slope) allowing the saturated areas of the
vegetated cover to drain and alleviate.
NORTHCAROUNAD_E Q�I
Uapartmmt of Envirentnental quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Zee Lamb
Page 2 of 7
July 8, 2019
2. Closed MSWLF —Impounded surface water
Donna Wilson, Solid Waste Section Permit Engineer, has reviewed the proposal and
the Section approves installing weep drains in settled areas of the terrace berm
ditches by July 31, 2019, to remedy the areas of impounded water over waste.
During installation, on -site monitoring is needed to minimize disturbance of the final
cover system, specifically the low -permeability infiltration layer. All areas where
vegetation is disturbed need to be re -seeded and stabilized. All areas addressed on the
MSWLF should be regularly inspected following the work to ensure ditches are
functional, areas with previous impounded water are relieved, and stabilization occurs.
Observed Violations
6401-MSWLF-1983 & 6401-CDLF-1999 (CLOSED LANDFILL)
1. Non -Water Supply Well Identification Plates
The Section approves the July 31, 2019 deadline for permanent identification plates to
be installed on MW5, MW3, MW6, and GP8 in compliance with state regulations.
Additionally, all monitoring wells at the facility should be inspected for compliance, well
structure integrity and security. Any observed issues should be addressed. The
inspection report as well as all repair actions should be documented and maintained in
the operating record.
2. Edge of Waste Markers
The Section approves the July 31, 2019 deadline for edge of waste markers to be
installed and/or replaced at minimum every 400-feet and at corners of the closed
facility.
Keep in mind during installation that the Edge of Waste Markers must be visible from
one to the other.
3. Repair to the Landfill Cap
a. ATVs Operating on the Landfill Cap
The Section approves the July 31, 2019 deadline for installing additional
signage as necessary and requesting increase in patrolling of the facility during
closed hours.
b. Damage to the Cap from heavy machinery
NORTHCAROUNAD_E Q��
DeparMett of EnNran—tal Duality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Zee Lamb
Page 3of7
July 8, 2019
The Section approves the July 31, 2019 deadline for all damage to the cap from
heavy machinery traffic to be repaired. Other routes to access the front
(northern) portion of the facility should be initiated, and the closed landfill
should not be used as a traffic route for heavy equipment.
c. Trees and woody shrubs growing on the closed landfill
The Section approves the June 30, 2019 deadline for maintenance by mowing
to be performed; and grants the July 31, 2019 deadline for all trees and
unwanted woody growth to be removed. Woody vegetation too large to
remove by mowing should be hand -cut at ground level and removed with
minimal disturbance to cap soils.
Going forward, an inspection schedule of the closed facility should be
implemented to identify potential issues and problem areas and to address in a
timely manner. A maintenance schedule should be implemented to maintain the
vegetation and more routinely eliminate unwanted growth.
6403-CDLF-2000 (OPERATING LANDFILL)
1. Burned Yard Waste from the Old Yard Waste Area
The Section approves the deadline of July 31, 2019 for the materials in this stockpile
that are substantially free of stumps and/or identifiable wood waste to be used in the
planned stabilization of the inactive portions of the operating CDLF.
All stumps and land clearing materials larger than can be used for this application,
must be treated as yard waste in accordance with Nash County Landfill's Operation
Plan, which states that yard waste will be ground, and Nash County Landfill's Permit
to Operate which states, "at least 75% by weight of recyclable and recovery material
must be removed from the site within one year." See the November 5, 2017 Fire
Incidence Report for historical information on this material.
2. Edge of Waste Markers
The Section approves the July 31, 2019 deadline for edge of waste markers to be
installed and/or replaced at minimum every 400-feet and at corners of the closed
facility.
Keep in mind during installation that the Edge of Waste Markers must be visible from
one to the other.
3. CDLF Cell No Longer Receiving Waste
NORTHCAROUNAD_E Q��
DeparMett of EnNran—tal Duality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Zee Lamb
Page 4 of 7
July 8, 2019
a. Exposed Waste
The Section approves the July 31, 2019 deadline for all areas with exposed
waste to be soil covered as required.
Incidental uncovered waste must be properly covered or removed and placed in
the active C&DLF.
b. No Vegetation and Erosion Rills on Side Slopes
The Section approves the July 31, 2019 deadline for all exposed soil covered
areas which will not have additional waste placed for three months or more,
but where final termination of disposal operations has not occurred to be
seeded and mulched.
Seeded areas should be inspected regularly; bare areas should be re -seeded and
mulched and managed in accordance to the approved sedimentation and
erosion control plan and 15A NCAC 13B .0542 (k). Additionally, going forward
all seeding events should be logged with a record of seeding activities
maintained on site.
4. Water Impounding on the Terracing of the CDLF Cell No Longer Receiving Waste
The Section approves the July 31, 2019 deadline for the CDLF to be re -graded to
prevent impounding of water.
All disturbed areas should be seeded and mulched.
S. Removal of Sediment in the Sediment Basin Near CDLF Cell No Longer Receiving Waste
The Section approves the July 31, 2019 deadline for the sediment basin to be cleaned
out, removing sediment and establishing the pond to approximate design grades.
Disturbed areas should be seeded and mulched upon completion.
6. The Cut in the Berm around the New CDLF Cell
a. Any changes to design or construction of the CDLF must be approved by the
Section
The Section approves the July 31, 2019 deadline for the berm around the new
C&DLF to be reconstructed per the approved plans.
Additionally, revised plans should be submitted to the Section that reflect the
County's desired removal of the soil berm between C&DLF Cells 4A and 413.
b. Leachate must be contained onsite or treated prior to discharge
NORTHCAROUNAD_E Q��
DeparMett of EnNran—tal Duality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Zee Lamb
Page 5of7
July 8, 2019
The revised Plan should describe landfill filling progression as to not impound
water in the active cell.
The County has suggested the possibility of using Cell 4B instead of Cell 4A
during periods of rain. The Section has reviewed Nash County Landfill's Permit
and determined that both cells can be in operation, however, be aware that
doing so could increase the amount of contaminated runoff that needs to be
managed.
TEMPORARY YARD WASTE AREA
1. Non -Conforming Wastes in the Yard Waste Area
The Section approves the July 31, 2019 deadline for all visible non -conforming waste
to be removed from the yard waste area and hauled to the landfill for disposal (C&D
wastes) or removed and managed as appropriate.
Nash County, Garrett & Moore, and Section staff discussed via conference call on June
28, 2019, that all non -conforming waste mixed in the yard waste debris (non -visible)
would be screened and removed at the time of processing the yard waste.
The Section strongly encourages Nash County to implement better methods of
screening the yard waste as it is received at the convenience sites or the landfill/yard
waste area. Unacceptable waste must be removed right away and not comingled with
the yard waste that will be processed.
2. Temporary Yard Waste Area was approved for one-year only on November 16, 2017
Nash County has proposed permitting a Land Clearing and Inert Debris (LCID) Landfill in
the vicinity of the current CDLF. The proposed time frame for submittal of the
application for the LCID is September 30, 2019.
The Section agrees that this is a viable course of action for dealing with any future
yard waste disposal.
However, until the LCID is approved, the County must manage yard waste in
accordance with Nash County Landfill's Operation Plan, which states that yard waste
will be ground, and Nash County Landfill's Permit to Operate which states, "at least
75% by weight of recyclable and recovery material must be removed from the site
within one year."
3. Ponding Water around or within Waste in Yard Waste Area
NORTHCAROUNAD_E Q��
DeparMett of EnNran—tal Duality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Zee Lamb
Page 6of7
July 8, 2019
The Section approves the July 31, 2019 deadline for grading of the temporary yard
waste area to allow positive drainage of surface water.
This site was approved for temporary use that has exceeded the limits of the approval.
Further, based on observations, this site appears to hold water. The section
recommends that Nash County look into approval of a more suitable area on the
property to receive and process Yard Waste until a more permanent solution is in
place.
DS64-006 (DISASTER -ASSOCIATED YW AREA)
Non -conforming Waste in the Disaster Debris Area
The Section approves the July 31, 2019 deadline for all visible non -conforming waste
should be removed from the disaster debris area.
Nash County, Garrett & Moore, and Section staff discussed via conference call on June
28, 2019, that all non -conforming waste mixed in the yard waste debris (non -visible)
would be screened and removed at the time of processing the yard waste.
2. Disaster Debris Waste and Non -conforming Waste had been Compacted and Buried
Nash County has proposed permitting a Land Clearing and Inert Debris (LCID) Landfill in
the vicinity of the current CDLF. The proposed time frame for submittal of the
application for the LCID is September 30, 2019.
The Section agrees that this is a viable course of action for dealing with future disaster
debris disposal.
However, until the LCID is approved and constructed, the County must manage
disaster debris in accordance with the approved DS64_006 Disaster Debris Emergency
Site Selection Evaluation Sheet which states the intended use of the Disaster Debris is
staging for chipping or burning (Nash County must have approval from the Division of
Air Quality for burning).
3. Closure should be accomplished within 6 months of initial site approval, which for this
site was March 13, 2019
The Section approves the July 31, 2019 deadline for the submittal of requested
information required to be granted an extension.
Nash County shall have the TDDSS closed out in the approved time of the extension
request approval.
NORTHCAROUNAD_E Q��
DeparMett of EnNran—tal Duality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 1 1646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Zee Lamb
Page 7 of 7
July 8, 2019
I will be conducting a follow up inspection the first week of August to see that corrective
actions have taken place at Nash County Landfill. Please keep the Section posted on future
progress. Should you have any questions about this letter, please feel free to contact me.
Sincerely,
Digitally signed by Davy Conners
DN: cn=Davy Conners, o=Division of Waste
Management, ou=Solid Waste Section,
email=[e-mail], c=US
Date: 2019.07.12 12:29:11-04'00'
Davy Conners
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
919-707-8290
cc: Ed Mussler, Solid Waste Section Chief, NC DEQ Solid Waste Section
Carolyn McClain, Assistant Attorney General
Jason Watkins, Field Operations Branch Head, NC DEQ Solid Waste Section
Andrew Hammonds, Eastern District Supervisor, NC DEQ Solid Waste Section
Jessica Montie, Compliance Officer, NC DEQ Solid Waste Section
Amanda Freeman, Compliance Officer, NC DEQ Solid Waste Section
Donna Wilson, Permit Engineer, NC DEQ Solid Waste Section
Ervin Lane, Hydrogeologist, NC DEQ Solid Waste Section
Ben Barnes, Nash County
Craig Fortner, Garrett & Moore, Inc.
Vance Moore, Garrett & Moore, Inc.
NORTH CAROLJNAD_E lv
Oepa6 of FmUenmm l flualz
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200