8606_RES_20200123

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined
MSWLF X LCID YW Transfer Compost SLAS COUNTY: Surry
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 8606-MSWLF-1998
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: January 23, 2020 Date of Last Inspection: December 5, 2019 & December 12, 2019

FACILITY NAME AND ADDRESS:
Surry County Municipal Solid Waste Landfill
237 Landfill Road
Mount Airy, North Carolina 27030

GPS COORDINATES: Lat.: 36.43185 Long.: -80.57530

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Jessica Montgomery, Public Works Director/County Engineer
Telephone: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Post Office Box 342
Dobson, North Carolina 27017

PARTICIPANTS:
Jessica Montgomery, Public Works Director/County Engineer – Surry County
Ricky Hawks, Public Works Office Coordinator – Surry County
Billy Southard, Landfill Coordinator – Surry County
Charles Gerstell, NCDEQ – Solid Waste Section

STATUS OF PERMIT:
A Permit Approval To Construct MSW Landfill Phase 4, Permit Approval to Operate MSW Landfill Phases 1, 2, & 3
and Notified (Less than 2 Acres) LCID Landfill, and Permit for Closure for 8602-MSWLF-1983 (Mt. Airy), 8602-
CDLF- (Mt. Airy), and 8602-CDLF-2011 (Mt. Airy) was issued to Surry County on October 18, 2018.

PURPOSE OF SITE VISIT:
Partial Inspection

STATUS OF PAST NOTED VIOLATIONS:
A. 15A North Carolina Administrative Code 13B .1626(2)(a) states: “Except as provided in Sub-Item (b) of this Item,
the owners or operators of all MSWLF units must cover disposed solid waste with six inches of earthen material at the
end of each operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing
litter, and scavenging.”

During an inspection on December 5, 2019, exposed waste was observed along a vertical slope on the west side of
Phase 1. The vertical slope was located at the transition point between Phase 1 and the new Phase 4 construction.
According to staff, this waste had been uncovered for over 1-month due to an issue with locating the edge of the
existing liner at the western edge of Phase 1. A tarp had been installed in the location of concern, but it covered only
a small portion of waste. The area of exposed waste was approximately 300-feet long X 20-feet tall. Reinspection
during an onsite meeting on December 12, 2019 found no improvement to this area.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 4

Exposed waste was also observed within inactive areas surrounding the working face of Phase 2 during the inspection
on December 5, 2019. An area of most concern was the inactive portion of the landfill immediately south of the
working face observed on both December 5th and December 12, 2019. Waste in the inactive portions of the landfill
had not been adequately covered at the end of the previous working day.

Surry County was found in violation of 15A NCAC 13B .1626(2)(a) in that waste was not covered with 6-inches of
earthen material or other Division approved alternative cover at the end of each operating day as required.

To achieve compliance, Surry County was required to cover all waste within the landfill, to include the transition
area between Phase 1 and Phase 2 with 6-inches of earthen material or an approved alternative cover material within
20-days of receipt of the Notice of Violation.

Inspection of the facility on January 23, 2020 found adequate soil cover within the MSWLF unit. The waste
previously exposed on the vertical slope at transition point between Phase 1 and the new Phase 4 construction had
been covered with synthetic tarps. As a result of the actions taken, this violation is considered resolved. Thank
you for your cooperation.

B. 15A North Carolina Administrative Code 13B .1626(8)(b) states: “Surface water shall not be impounded over or
in waste.”

During the December 5th and December 12, 2019 inspections, standing water was observed within the trench
located along the transition area between Phase 1 and the new Phase 4 construction. Waste exposed from the
excavated, vertical slope was observed within the standing water. Therefore, Surry County was found in violation
of 15A NCAC 13B .1626(8)(b) for allowing surface water to be impounded in waste.

To achieve compliance, Surry County was required to take immediate steps to collect and properly dispose of any
leachate within the transition area between Phase 1 and the new Phase 4 construction, as well as install and maintain
temporary measures to prevent and/or control any future leachate generated until the necessary permanent repairs
are complete.

Since the previous inspection, Surry County installed a diversion ditch along the eastern perimeter of the new Phase
4 construction to direct stormwater away from the area of concern. A pump was also being utilized to remove water
adjacent to the vertical slope which was routed to a leachate cleanout. Tarps installed along the vertical slope of
Phase 1 had been extended across the bottom of the ditch at the toe of the slope to prevent water from contacting
waste. The liner system was being installed in the new Phase 4 construction area which will eventually tie into the
liner system along the western perimeter of Phases 1 and 2. As a result of the actions taken, this violation is
considered resolved. Please continue to maintain all measures to prevent a reoccurrence of the subject
violation.

C. 15A North Carolina Administrative Code 13B .1626(8)(d) states in part: “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.”

During the December 5th and December 12, 2019 inspections, water was observed comingled with waste within the
trench located at the transition area of Phase 1 and the new Phase 4 construction. Leachate means any liquid,
including any suspended components in liquid, that has percolated through or drained from solid waste. A portion of
the exposed liner within the area of impoundment had been misplaced and damaged as a result of efforts to locate the
edge of liner. Therefore, all observations point to a violation of 15A NCAC 13B .1626(8)(d) in that leachate was
allowed to accumulate in this area and was not contained within the leachate collection and storage system.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 4

To achieve compliance with this rule, Surry County was required to take immediate steps to collect and properly
dispose of any leachate within the transition area between Phase 1 and the new Phase 4 construction, as well as install
and maintain temporary measures to prevent and/or control any future leachate generated until the necessary
permanent repairs were complete. The Section issued a letter to Surry County on December 16th with specific
questions as to an assessment of conditions and the proposed repairs needed.

Since the previous inspection, Surry County installed a diversion ditch along the eastern perimeter of the new Phase 4
construction to direct stormwater away from the area of concern. A pump was also being utilized to remove water
adjacent to the vertical slope which was routed to a leachate cleanout. Tarps installed along the vertical slope of
Phase 1 had been extended across the bottom of the ditch at the toe of the slope to prevent water from contacting
waste. The liner system was being installed in the new Phase 4 construction area which will eventually tie into the
liner system along the western perimeter of Phases 1 and 2. As a result of the actions taken, this violation is
considered resolved. Please continue to maintain all measures to prevent a reoccurrence of the subject
violation.

D. 15A North Carolina Administrative Code 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”

x Attachment 2, Part I of the approved permit states in part:

¾ “(2) Construction of all solid waste management units within this facility must be in accordance with
the pertinent approved plans and only for those phases of development approved for construction as
described in Attachment I, Part II List of Documents for the Approved Plan.”

¾ “(4) Modifications or revisions of the approved documents or changes during construction of any
landfill unit/cell require approval by the Section.”

Surry County was found in violation of 15A NCAC 13B .0203(d) and permit conditions in that Phase 4 construction
revealed inconsistencies in previously submitted drawings and observed field conditions as it relates to the liner tie-
in., which had in part lead to the violations noted above. In addition, changes to the entrance road had been made.
The Section was not notified on these items in advance of the December 5th and 12th site visits, and therefore any
changes were not approved by the Section.

To achieve compliance, Surry County was required to supply the information requested in the December 16th letter
and implement any changes required prior to completion of the liner tie-in between existing Phase 1 and future Phase
4. A response to the letter issued by the Section was received at the Asheville Regional Office on January 9, 2020.
The information satisfied the Section’s request for additional information. Therefore, this violation is considered
resolved. Please refer to the subsequent letter from Allen Gaither, Environmental Engineer, dated January 13,
2020 for the Section’s response to the County’s submittal.

OBSERVED VIOLATIONS:
No new violations 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.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 4

ADDITIONAL COMMENTS

1. The facility is permitted to receive waste generated within a 90-mile radius of Surry County.
2. The facility consists of a lined municipal solid waste landfill unit, white goods area, tire collection area, a less than
2-acres Land Clearing and Inert Debris Unit, and a recycling area for the collection of paper, cardboard, glass and
plastic containers, aluminum, steel cans, batteries, cooking oil and electronics.
3. This was a partial inspection to evaluate the facility’s efforts to comply with the Notice of Violation issued to Surry
County on December 20, 2019. Please see “Status of Past Observed Violations” for comments.

Operations Inspection of the MSWLF Unit:

4. Waste was being placed in the eastern portion of Phase 2 at the time of inspection.
5. The working face was very small and compact.
6. No unacceptable waste streams were observed.
7. Windblown waste was well controlled.
8. The liner system was being installed in the new Phase 4 at the time of inspection.

Please contact me if you have any questions or concerns regarding this inspection report.

________________________________________ Phone: [phone]
Charles T. Gerstell
Environmental Senior Specialist
Regional Representative

Sent on: 1/31/20 X Email Hand delivery US Mail Certified No.:

Copies: Chris Knopf, Surry County Manager
Jason Watkins, Field Operations Branch Head (SWS)
Deb Aja, Western District Supervisor - Solid Waste Section (SWS)

Digitally signed by Charles T. Gerstell
DN: cn=Charles T. Gerstell, o=Divsion of
Waste Management, ou=Solid Waste
Section, email=[e-mail],
c=US
Date: 2020.01.31 14:26:43 -05'00'