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HomeMy WebLinkAbout6708_INSP_20190711FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section UNIT TYPE: Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: Onslow Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 6708-MSWLF-1997 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Inspection: 11 July 2019 Date of Last Inspection: 18 May 2017 FACILITY NAME AND ADDRESS: MCB Camp Lejeune MSW Landfill Piney Greene Road Camp Lejeune, NC 28452 GPS COORDINATES: N: 34.69065 E: -077.32384 FACILITY CONTACT NAME AND PHONE NUMBER: Joe Powers 910.451.4998 FACILITY CONTACT ADDRESS: U. S. Marine Corps Camp Lejeune MSWLF C/o Commanding General AC/S Facilities (Maintenance/Utilities) CP Lejeune PSC Box 20004 Camp Lejeune, NC 28452 Attn: Joe Powers e-mail: joseph.powers@usmc.mil PARTICIPANTS: Amy Humphrey-Carraway; MCB Camp Lejeune Landfill Operations Kevin Foster; MCB Camp Lejeune Landfill Operations Thomas Richard; Environmental Engineer/MCB Camp Lejeune EMD Jason Watkins; NCDEQ/Solid Waste Ray Williams; NCDEQ/Solid Waste STATUS OF PERMIT: Active; Permit to Construct (PTC) Phase IV and Permit to Operate (PTO) Phase III issued 13 May 2014. The Phase III PTO expires 20 May 2024. PURPOSE OF SITE VISIT: Partial Facility Compliance Inspection without records review. STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS: 1) 15A NCAC 13B .1604 (2) (A) states “Duty to Comply. The permittee shall comply with all conditions of the permit.” 2) 15A NCAC 13B .1604 (2) (B) states “Duty to Mitigate. In the event of noncompliance with the permit, the permittee shall take all reasonable steps to minimize releases to the environment, and shall carry out such measures as are reasonable to prevent adverse impacts on human health or the environment.” FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section 6708_INSP_20190711 Page 2 of 6 3) 15A NCAC 13B .1604 (2) (I) states “Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of the permit.” 4) 15A NCAC 13B .1626 (6) (b) states “An attendant shall be on duty at the site at all times while it is open for public use to ensure compliance with operational requirements.” 5) 15A NCAC 13B .1626 (7) (a) states “Adequate sediment control measures (structures or devices), shall be utilized to prevent silt from leaving the MSWLF facility. 6) 15A NCAC 13B .1626 (7) (b) states “Adequate sediment control measures (structures or devices), shall be utilized to prevent on-site erosion.” 7) 15A NCAC 13B .1626 (8) (b) states “Surface water shall not be impounded over or in waste.” 8) 15A NCAC 13B .1626 (8) (c) states “Solid waste shall not be disposed of in water.” 9) 15A NCAC 13B .1626 (8) (c) states “Leachate shall be contained within a lined disposal cell or leachate collection and storage system. All leachate shall be treated, as required by the receiving facility, prior to discharge. An NPDES permit may be required prior to the discharge of leachate to surface waters, as provided by 40 CFR Parts 258.26 and 258.27.” 10) 15A NCAC 13B .1626 (11) (c) states “Methods such as fencing and diking shall be provided within the area to confine solid waste subject to be blown by the wind. At the conclusion of each day of operation, all windblown material resulting from the operation shall be collected and returned to the area by the owner or operator.” 11) 15A NCAC 13B .1626 (12) (a) states “The owner or operator of a MSWLF unit designed with a leachate collection system must establish and maintain a leachate management plan which includes the following: Periodic maintenance of the leachate collection system;” 12) 15A NCAC 13B .1626 (12) (e) states “The owner or operator of a MSWLF unit designed with a leachate collection system must establish and maintain a leachate management plan which includes the following: A contingency plan for extreme operational conditions.” Within the ADDITIONAL COMMENTS section below are details concerning the violations listed above and the necessary corrective actions that must be undertaken are in bold print. ADDITIONAL COMMENTS: 1) This landfill is a lined Municipal Solid Waste Landfill. 2) This landfill is permitted to receive solid waste generated by and on Marine Corps Base Camp Lejeune, Marine Corps Air Station Cherry Point, and all related ancillary Marine Facilities. 3) The landfill facility is secured by means of a locked gate at the facility entrance during non-operational hours. 4) Proper signage is posted at the entrance to the facility stating the permit number, contact information, and listing banned/excluded wastes. 5) Hours of operation for this Facility are Monday through Friday 7:30 AM to 3:30 PM, except the landfill is closed on ten holidays: New Year’s Day, Martin Luther King Jr Day, President’s Day, Memorial Day, Independence Day, Labor Day, Columbus Day, Veteran’s Day, Thanksgiving Day, and Christmas Day. 6) The facility access road is of all-weather construction and is being well maintained at this time. 7) This facility manages landfill gas through a passive venting system. 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 6708_INSP_20190711 Page 3 of 6 8) Edge of liner markers have been installed throughout the landfill and are being maintained as required. 9) This landfill is currently operating in Phase III. Construction of Phase IV has been completed. 10) This Facility requires five-day advance notice for the receipt of asbestos containing materials. All received asbestos waste is disposed in an area adjacent to the working face, covered upon receipt, and mapped with a GPS unit. 11) Soil is stockpiled adjacent to the active working face for use as cover. 12) The working face is being maintained in a compact and manageable size. 13) The waste type was reviewed during this Facility Compliance Inspection. Only MSW was observed at the working face. 14) No attendant was present at the working face during this part of the Facility Compliance Inspection. *Please ensure that an attendant is always present at the working face when this Facility is open and receiving waste for disposal. 15) The landfill waste compactors were non-operational during the time of the inspection due to repairs being needed and not funded. Minimal compaction of waste was occurring during placement of cover utilizing a bulldozer. Not having properly operating equipment to compact trash is inefficient, and can lead to loss of airspace (cell filing up faster than planned), changes in leachate and landfill gas production, the potential for stability issues within the waste mass, and potential for side slope failure. * Repairs to or replacement of the compactors should be undertaken immediately to prevent future impacts to the landfill and unnecessary spending of funds to offset issues that could have otherwise been prevented. 16) Surface waters are being channeled in an uncontrolled manner along the toe of Cell #7 causing erosion of the landfill cap system. *Control structures, such as check dams need to be placed in the ditch line to slow the flow of stormwater and prevent future eroding of the landfill side slope. 17) Solid waste materials, either non-collected windblown debris or exposed due to erosion of the side slope cover, has been conveyed by surface waters to the eastern side slope of Cell #8. All solid waste should be collected and returned to the working face daily. *All solid waste found outside of the active working area needs to be collected and properly disposed at the working face daily. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section 6708_INSP_20190711 Page 4 of 6 18) An area of ponding/standing water was observed along the eastern toe of Cell #8. While this appears to be within the lined cell, waste materials were observed in contact with water and landfill gas was observed causing bubbling or rippling of the water in this area. *Within thirty days of receipt of this Facility Compliance Inspection Report, all ponding/standing water currently in the landfill should be pumped to the leachate collection system and properly managed as leachate. The area collecting this water should be filled, graded, and maintained in such a way at to promote the positive flow of surface waters away from the landfill. All water that comes in contact with solid waste should be properly managed as leachate. 19) The perimeter berm of Cell #8 was damaged/washed out during the Hurricane Florence storm event in September 2018 around the leachate pump station. While some soil appears to have been placed in the area, this damage has not been adequately repaired. In addition, the Cell #8 leachate pump and pump station were also damaged at this time and have not been repaired. The washout also appears to have potentially damaged to the liner system. *Within thirty days of receipt of this Facility Compliance Inspection Report, the facility shall submit a work plan for approval detailing how the damage to the perimeter berm of the landfill, the leachate pump/pump station, and the liner system will be repaired to the specifications set forth in your approved facility construction plans. Upon completion of the repairs, construction quality assurance (CQA) documentation stamped by a licensed professional engineer shall be submitted to the Section. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section 6708_INSP_20190711 Page 5 of 6 20) Free liquid (possibly leachate) was observed to be seeping through and/or around the damaged area of the liner system noted in item 18 above. *Actions should be taken to determine what the liquid is and its source. If it is landfill leachate, actions should be undertaken to immediately stop the release, and any repairs necessary should be included in the work plan required by Item 18 above. 21) *The facility shall undertake soil sampling between this area described in Items 18 & 19 and the landfill access road, as well as surface water sampling in the stormwater basin downgradient of the area, to determine if a leachate was released from the landfill in this area. A sampling protocol is attached to this report. Additional correction action may be required depending on the results of the sampling. 22) Leachate is stored in a lined on-site leachate management pond. The pond is secured by a locked chain link fence. The gate was closed and locked during this Facility Compliance Inspection. The pond is well maintained, and no areas of erosion were observed during this Facility Compliance Inspection. 23) Overall, the closed areas of the landfill are well maintained with a well-established cover crop of native warm season grasses. However, areas of sparse cover and erosion were observed on the eastern outside slope of Phase II. *Within thirty days of receipt of this Facility Compliance Inspection Report, please fill and grade all eroded areas at a slope not greater than 3:1. These areas should be seeded and mulched to establish a groundcover suitable to prevent erosion of your landfill cap system. Any other areas where the groundcover is unsuitable to prevent erosion of your landfill cap system should be seeded and mulched promptly. 24) The landfill stormwater management basins were reviewed. Overall, the ponds were clear of windblown litter and brush, and no areas of erosion were observed around the pond margins during this Facility Compliance Inspection. 25) The soil borrow area was reviewed. Areas of erosion were observed near and in the stormwater management basin. *Within thirty days of receipt of this Facility Compliance Inspection Report, plans need to be underway for the repair of these areas. All eroded areas should be filled, graded, seeded and mulched to establish a cover crop suitable to prevent erosion. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section 6708_INSP_20190711 Page 6 of 6 26) *Corrective measures are required as a result of this Facility Compliance Inspection. Please contact me if you have any questions or concerns regarding this Facility Compliance Inspection Report. Ray Williams; Environmental Senior Specialist Phone: 252.948.3955 E-mail: ray.williams@ncdenr.gov Regional Representative Delivered on 5 August 2019 by Electronic delivery US Mail X Certified No. [7018 0360 001 9842 8485] cc: Michael Scott, DWM Division Director: michael.scott@ncdenr.gov Ed Mussler, Section Chief/SWS: ed.mussler@ncdenr.gov Sherri Stanley, Permitting Branch Head: sherri.stanley@ncdenr.gov Jason Watkins, Field Operations Branch Head/SWS: jason.watkins@ncdenr.gov Andrew Hammonds, Eastern District Supervisor/SWS: andrew.hammonds@ncdenr.gov Jessica Montie, Environmental Program Consultant/SWS: jessica.montie@ncdenr.gov Thomas Richard, Environmental Engineer/MCB Camp Lejeune EMD: thomas.richard@usmc.mil C: \2019\Onslow\Facilities\67-08\Inspections\6708_INSP_20190711 NCDEQ DWM Laserfiche Online Document Management System: https://edocs.deq.nc.gov/WasteManagement/Browse.aspx?startid=8   Go Green! Thank you for helping NCDEQ be environmentally responsible.