3406_INSP_20200116

oepamnem a� enmmnmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: Forsyth
MSWLF
PERMIT NO.: 3406-MSWLF-1989
Closed
X
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: January 16, 2020 Date of Last Inspection: August 7, 2018
FACILITY NAME AND ADDRESS:
Piedmont Sanitary Landfill — Closed
9901 Freeman Road
Kernersville, NC 27284
GPS COORDINATES: Lat.: 36.195582 ° Long.: 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 — LaBella Associates
Rochelle Mesubed — LaBella Associates
Susan Heim, Environmental Senior Specialist — Solid Waste Section
STATUS OF PERMIT:
Closed MSW Landfill
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
1. RESOLVED: 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
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
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Solid Waste Section
analytical results from the laboratory.
The soil sampling plan was implemented as approved, and a Leachate Release Assessment Report,
dated August 13, 2018, was submitted to Christine Ritter, Solid Waste Section Hydrogeologist. After
reviewing the report, Ms. Ritter stated, in an email dated August 31, 2018, that no further action
regarding soil and surface water in the vicinity of the leachate release would be required at that time.
Action completed.
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 the 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.
In a letter dated July 20, 2018, Mr. Lacsamana provided data about leachate generation and disposal
from 2005 through June 2018, as well as a 1992 drawing showing the drain line from the old wash pad.
He stated that it was his belief that the line was capped and abandoned prior to construction of Phase 3
of the landfill; no additional records are available. Action completed.
3. Submit a detailed written description, including waste disposal receipts, etc., of where any excavated soils
have been stockpiled and their final disposition.
In an email dated September 24, 2018, Mr. Burbach provided documentation of the disposal of 101.41
tons of soil that had been removed from the leachate release site. Disposal took place between August
21 and 23, 2018 at the Hanes Mill Road Landfill (Permit # 3402). Action completed.
4. Submit a detailed written description of any impacts to the adjacent Kemersville Landfill facility, located
adjacent to the leachate cleanout along Freeman Road.
The Leachate Release Assessment Report, dated August 13, 2018, concluded that the incident had no
significant impact or threat of impact to the adjoining Town of Kernersville property. Action
completed.
OBSERVED VIOLATIONS:
No new violations were observed.
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.
ADDITIONAL COMMENTS
1. The facility is secured by means of perimeter fencing that prevents prohibited entry using locking gates at the
entrance and several other access points. Proper signage was observed at the entry gate.
2. Facility roadways are of all-weather construction with a stone base. Roadways appeared to be in good
condition, although the saturation of the ground along the southern portion of the roadway precluded driving to
the western end of the landfill unworkable.
3. The landfill cap was observed to have a well -established vegetative cover comprised of a mixture of native
grasses and lespedeza. At the time of this inspection, the vegetation had grown to a height of several feet. Small
trees were found growing on several areas of the landfill cap. Mr. Lacsamana stated that the landfill is mowed
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Solid Waste Section
twice a year. Please ensure that the small trees found growing on the cap are removed, and repairs are
made to ensure the continued integrity and effectiveness of the cap, as required by 15A NCAC 13B
.1627(d)(1)(A).
4. Slope terraces and drains appeared to be functioning properly. No evidence of erosion was observed on the
landfill cap.
5. The perimeter ditch line at the toe of the landfill slope is lined with a synthetic matting to help maintain the
integrity of the ditch design. The perimeter ditch and other ditches on the landfill slopes appeared to be
functional and in good condition. No ponding water was observed.
6. One area of the landfill cap, located near the center of the top, had been a concern during previous inspections.
A portion of the slope had failed and had been difficult to repair and maintain. However, during this inspection,
the area appeared to have adequate vegetative cover. Mr. Lacsamana pointed out that the white stakes used to
cordon the area off from mowing operations during germination have been left in place in order to continue to
protect the new vegetation as it becomes fully established.
7. Several of the groundwater monitoring wells were observed from the vehicle and appeared to be well -
maintained and accessible, with proper construction, protection, and labeling in place.
8. Maintenance of the sumps was taking place during the inspection. A contractor was observed working in the
area of Sump 7 on the southwest slope of the landfill. Mr. Lacsamana stated that these repairs will eliminate
some system issues and ensure that the entire leachate collection system functions as designed.
9. The leachate tank area was observed next. Mr. Lacsamana stated that the perimeter fencing that had been
installed to enclose the tanks, the secondary containment and the access roadway had virtually eliminated the
frequent problem of illegal dumping at the site.
10. The five leachate storage tanks were inspected. Chest -high weeds had grown up around the outside of the
secondary containment wall. Mr. Lacsamana stated that the tank area is mowed twice a year, along with the
landfill cap.
11. The leachate tanks appeared to be stained. Vertical brown streaks were visible on the outside walls of the tanks.
Mr. Lacsamana stated that the tanks are not constructed of metal, so the streaks are not rust. He added that the
telemetry system has not indicated any leaks or failures in the tanks or the piping that is connected to them, so
the stains are not the result of leachate either. Mr. Lacsamana stated that he intends to pressure wash the tanks
and the entire containment area, and suggested that this might remove the stains on the tanks.
12. From outside the secondary containment area, the system of pipes and valves appeared to be intact. No leaks
were observed. However, much of the insulation on the piping has split and worn away or fallen off altogether.
Mr. Lacsamana stated that the deterioration of the pipe insulation makes it necessary to add new insulation to
the newly exposed areas regularly.
13. Ms. Mesubed stated that she performs the quarterly landfill gas monitoring and also inspects the tanks during
each visit to the site. Mr. Lacsamana explained that Ms. Mesubed performs a casual inspection of the entire
facility during her visits and informs him of any areas of concern that she spots or repairs that she feels are
needed.
14. The gas plant was observed in passing and appeared to be functioning normally. The plant itself is situated on a
gravel pad, with access from the perimeter roadway on the north side of the landfill. The entire gas plant was
found to be clean and well -maintained.
15. Mr. Burbach provided landfill gas and groundwater monitoring records for the previous calendar year.
16. Groundwater monitoring has been approved to take place only annually at the facility. The most recent
groundwater sampling event occurred on March 13 and 14, 2019. Additional samples were pulled on May 21,
2019.
17. Landfill gas monitoring is performed quarterly, as required. Facility records confirmed that sampling events
took place on January 8, 2019, May 1, 2019, July 2, 2019, and October 15, 2019.
18. At the time of this inspection, information concerning the annual adjustment of the post -closure cost estimate
for the financial assurance had not been provided to the Solid Waste Section. Please provide a copy of the
current, adjusted financial assurance instrument as required by 15A NCAC 13B .1628(c)(1)(B).
19. Please provide a copy of the leachate generation and disposal records for the calendar year 2019.
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DO Ctd—iA
OepaNnen� e� Envimmenlal Oualiry
Solid Waste Section
A close-up view of 3 of
the leachate storage
tanks. Note the
discoloration of the
tank walls - vertical
streaks on the tank in
the right foreground
and a horizontal ring
around the bottom of
the tank with the
piping connected to it.
The deteriorated pipe
insulation is also
visible, along with the
high weeds found
growing around the
outside of the
secondary containment
wall.
A section of the lined perimeter ditch
with a slope drain that empties into it.
The ditch liner minimizes the need for
ditch maintenance and helps to ensure
that the drainage system functions
properly.
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oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A view of the closed landfill entry gate with the terraced slope of the south side of the landfill in the background.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan
Heim
DN: cn=Susan Heim,
o=Solid Waste Section,
ou=Field Operations
Branch,
email=susan.heim@ncdenr.
gov,c=US
Date: 2020.01.22 13:37:14
-05'00'
Susan Heim
Environmental Senior Specialist
Regional Representative
Phone: [phone]
Sent on: January 22, 2020 to
X
Email
Hand delivery
US Mail
Certified No. [ ]
Al Lacsamana, Waste
Management, Inc.
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
Sarah Rice, Compliance Officer — Solid Waste Section
Van Burbach, Senior Technical Consultant — Joyce Engineering, Inc.
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