7304_INSP_20200812

NORTH CARnLINAD_E Q�/��
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
X
LCID
YW
Transfer
compost
SLAS
COUNTY: PERSON
MSWLF
PERMIT NO.: 7304-MSWLF-1997
Closed
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofll
Landfill
Date of Site Inspection: August 12, 2020
FACILITY NAME AND ADDRESS:
Republic Services of North Carolina, LLC
d.b.a. Upper Piedmont Regional Landfill
9650 Oxford Road
Rougemont, NC 27572
GPS COORDINATES: 36.32567°,-78.83028'
Date of Last Inspection: March 26, 2020
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Erik Seibold
[e-mail]
336-390-1301 (o); 478-697-0397 (c)
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS:
Davy Conners, NC DEQ — Solid Waste Section
Amanda Thompson, NC DEQ — Solid Waste Section
Erik Seibold, Republic Services
Matt Einsmann, Republic Services
Eric Spencer, Republic Services
STATUS OF PERMIT:
Permit to Construct MSWLF Phase 3 and Operate MSWLF Phase 1, 2, and 3 (Calls 5A and 6A) was issued August 20,
2018. In accordance with North Carolina General Statute 130A-294(a2), permits for sanitary landfills and transfer
stations shall be issued for the life -of -site of the facility unless revoked. Life -of -site ends when the facility reaches its
final permitted elevations or by June 24, 2057.
PURPOSE OF SITE VISIT:
Pre -construction meeting and follow-up compliance inspection
STATUS OF PAST NOTED VIOLATIONS:
None
Page 1 of 7

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
OBSERVED VIOLATIONS:
A. 15A NCAC 13B .1626 (2)(a), "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 he end of each
operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing
litter, and scavenging."
Upper Piedmont Regional Landfill is in violation of 15A NCAC 13B .1626 (2)(a) in that adequate earthen material
had not been applied to cover all of the disposed solid waste. During the inspection, large amounts of exposed
waste was observed on the top tier of the landfill. Waste had not been disposed of in this area for a few weeks.
(Figures 1-3)
B. 15A NCAC 1313.1626 (8)(d), "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."
Upper Piedmont Regional Landfill is in violation of 15A NCAC 13B .1626 (8)(d) in that leachate had not been
contained within the collection system. The day prior to the inspection, Matt Einsmann notified the Section of a
leachate release that had flowed from the landfill into the forebay of Basin 2. Upper Piedmont worked to contain
the release in the forebay. During the inspection, the release had been stopped however several leachate seeps
were observed and the original area that caused the leachate release had not been fully repaired. (Figures 4-5).
See "Corrective Actions" below for the required measures necessary to resolve these violations.
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
Upper Piedmont Regional Landfill, 7304-MSWLF-1997, is permitted to operate Phase 1 (Cells IA, 2A, 3A, and 4A),
Phase 2 (Cells 113, 213, 313, and 413) and Phase 3 (Cells 5A and 6A) of the municipal solid waste landfill. The facility is
approved to accept an average maximum annual disposal rate is 660 tons per day, 365 days per year, or 240,900 tons per
year in accordance with the franchise approved by Person County Board of Commissioners. The facility is looking to
increase that amount to 780,000 tons per year.
The following issues were observed during the March 26, 2020 inspection, and the current status is listed. Action is
needed to resolve these compliance concerns.
PARTIALLY RESOLVED: During the March 2020 inspection, the upper tier of the north, west and
southwest slopes of the landfill had little to no vegetative cover. In December of 2019, the slopes had been
reworked using the sliver fill technique to reach final grade resulting in the disturbance of the vegetation on these
slopes. During the August 2020 inspection, seed and mat had been applied, however very little vegetation was
present.
2. UNRESOLVED: Erosion rills were observed on the slopes of the landfill (Figure 6). All required sedimentation
and erosion control measures must be installed and operable to mitigate excessive on -site erosion.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"'­ t0E ! 'm"""°"""' Solid Waste Section
In addition to the items listed above, the following issues were observed during the inspection on August 12, 2020 and
require action to resolve:
1. Large plumes of dust were produced from trucks traveling on the road to the top of and surrounding the
landfill (Figure 7). The landfill must be operated and maintained with sufficient dust control measures to minimize
airborne emissions and to prevent dust from becoming a nuisance or safety hazard. A dust control truck was in
used at the beginning of the inspection and was spraying water on the road; however, it was not enough to suppress
the dust.
2. Groundwater monitoring well MW2 was open and unlocked. All non -water supply wells, including temporary
wells, must be secured with a locking well cap to ensure against unauthorized access and use.
3. Water was observed ponding in small amounts on the top tier of the landfill (Figure 8). Surface water must be
diverted from all operational and storage areas to prevent standing water in operational areas.
CORRECTIVE ACTION:
1. Immediately apply six inches of soil cover to all areas of exposed waste, including areas along the service
road to the top of the landfill and any areas of exposed waste due to erosion. On August 13, 2020, Erik
Siebold emailed photo evidence (Attachment II, Figure A) of the upper deck with adequate soil cover. Make sure
all other areas of the landfill also have adequate soil cover.
2. In response to the leachate release, immediately identify the cause of the release and seeps and take action
to stop it.
Within 15 days of receipt of this report, submit a Sampling Plan for Section approval prior to sampling.
The proposed plan shall be submitted in electronic format sent via email to Davy Conners at
davis.connersAncdenr.gov and Ervin Lane at ervin.lane(a,ncdenr.gov and meet the following
requirements:
a. Include a map/aerial photo depicting area of impact and proposed sampling locations;
b. Provide a description of the proposed sampling methodology; and
c. Describe proposed subsurface soil sampling and surface water sampling (if applicable) at specific
locations, including background soil and upstream water locations, to evaluate the extent of the
potential environmental impacts from the release(s) at the facility;
i. Subsurface soil samples shall be collected between one to two feet below ground surface;
ii. Discrete soil samples shall be collected. Composite samples will not be accepted; and
iii. All soil and surface water samples shall be analyzed by a NC certified laboratory for 40
CFR Part 258 Appendix I parameters (VOCs and Total Metals), total phosphorus, sulfate,
nitrate, and pH.
After Section approval of the sampling plan, the plan shall be implemented within seven (7) days. Within
10 business days after receiving the analytical results from the laboratory, submit documentation
regarding the sampling event which shall include the following:
a. A summary of the leachate release, actions taken to address the release, and the release assessment;
b. A map/aerial photo depicting the sampling locations;
c. A table of the surface water analytical results compared to the NCDWR Surface Water Quality
Standards & Protective Values;
d. A table of the subsurface soil analytical results compared to the NCDEQ Preliminary Soil
Remediation Goals (PSRGs). Both the Residential Health Based and the Protection of
Groundwater PSRGs must be met;
e. The associated laboratory reports from the NC certified laboratory including the chain of custody
and QA/QC results;
f. The sampling methodology, if different from the proposed plan; and
Page 3 of 7

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
Solid Waste Section
g. Conclusions and recommendation
3. When weather permits, reseed the side slopes to establish a vegetative cover.
4. Within 30 days of receipt of this report, apply soil cover to the erosion rills and implement erosion control
measures necessary to stop onsite erosion.
5. Immediately begin taking necessary measures to control dust emissions.
6. Within 15 days of receipt of this report, close and secure all monitoring wells.
7. Within 15 days of receipt of this report, regrade areas of ponding water on the landfill to promote drainage
such that surface water does not impound over waste.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Davy Conners
i \ DN: cn=Davy Conners, o=Division of Waste
1Uu_ ti.J Management,ou=Solid Waste Section,
Email: [e-mail]
,!�.�,,,
_ `- email=[e-mail], c=US
- Date: 2020.08.17 13:12:52 -04'00'
Phone: [phone]
Davy Conners
Environmental Senior Specialist
Regional Representative
Sent on: August 17, 2020 X Email Hand delivery US Mail Certified No. !j
Copies: Andrew Hammonds, Eastern District Supervisor — Solid Waste Section
Ervin Lane, Hydrogeologist — Solid Waste Section
Amanda Thompson, Environmental Senior Specialist — Solid Waste Section
Page 4 of 7

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
OepaNnenY of Environmental 0ualiry
Solid Waste Section
Attachment I: Inspection Photos
Taken by Davy Conners, August 12, 2020
Ylrlk ✓ � 1 _-.:.RrF s'._-L&.,.` :';'t,,. .„ 1 ��_ 1 •-.'ay,
Figure 1: Exposed waste
Fi e 2: Exposed waste
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Fi ure 3: Ex osed waste
Figure 4: Leachate release
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Figure 5: Leachate seep
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Figure 6: Erosion rill
Page 5 of 7

NORTH CAR()LINAD_E Q��
OepaNnent of Envieanmenbl [1uel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 7

FACILITY COMPLIANCE INSPECTION REPORT
��n1��;poii�
D_E Q�� Division of Waste Management
OepaNmen iEnvironmental0ualiry
Solid Waste Section
Attachment II: Post -inspection Photo
Sent by Erik Siebold on August 13, 2020
Figure A: Upper deck of landfill with soil cover
Page 7 of 7