4302_INSP_20200828

NORTH CAR()LINAD_E Q��
OepaNnent of Envimnmenbl [1uel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
X
Yw
X
Transfer
Compost
SLAS
COUNTY: HARNETT
MSWLF
PERMIT NO.: 4302-CDLF-1998
Closed
X
xxW
white
X
Incin
T&P
FIRM
MSWLF
goods
4302-CDLF-2018
4302-MSWLF-1988
4302-LCID-1998
FILE TYPE: COMPLIANCE
Coil
X
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofrll
Landfill
Date of Site Inspection: August 26, 2020 Date of Last Inspection: April 26, 2017
FACILITY NAME AND ADDRESS:
Harnett County Dunn -Erwin Landfill
449 Daniels Road
Dunn, NC 28334
GPS COORDINATES: Lat.: 35.36564 Long.:-78.64981
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Andrew Holland
Phone: [phone]
Email address: mholland(c-r�,hamett.org
FACILITY CONTACT ADDRESS:
Chad Beane
Harnett County Solid Waste Director
PO Box 2773, Lillington, NC 27546
Phone: [phone] Fax: [phone]
PARTICIPANTS:
Amanda Thompson, NCDEQ, Solid Waste Section
Drew Hammonds, NCDEQ Solid Waste Section
Andrew Holland, Harnett County Dunn -Erwin Landfill
STATUS OF PERMIT:
4302-LCID-1998 Permit to Operate issued May 26, 2015. Permit expired on May 26, 2020. Permit renewal paperwork
was submitted 5/22/2020.
Life of Site Permits issued for 4302-CDLF-1998 and 4302-CDLF-2018 on July 23, 2020. The Life of Site Permits will
expire on March 2, 2058.
PURPOSE OF SITE VISIT:
Partial Compliance Inspection of all facilities and introduction of Amanda Thompson, ESS.
STATUS OF PAST NOTED VIOLATIONS:
None
Page 1 of 9

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"'­ t0E ! 'm"" lW'Ift Solid Waste Section
OBSERVED VIOLATIONS:
A. 15A NCAC 13B .0542 (f)(1), " Except as provided in Subparagraph (3) of this paragraph, the owners and
operators of all C&DLF units must cover the solid waste with six inches of earthen material when the waste
disposal area exceeds one-half acre and at least once weekly. Cover must be placed at more frequent intervals
if necessary, to control disease vectors, fires, odors, blowing litter and scavenging."
The Harnett County Dunn -Erwin Landfill is in violation of 15A NCAC 13B .0542 (f)(1) in that adequate earthen
material had not been applied to cover all the disposed solid waste. Mr. Andrew Holland stated during this inspection
that the landfill was short staffed, and Area 2 waste had not been covered in a few weeks. At the time of this
inspection, it appeared that the exposed waste at the active working face of CDLF Area 2 was more than one acre
in size.
B. 15A NCAC 13B .0542 (1)(4), "Leachate must be contained on -site or treated prior to discharge."
The Harnett County Dunn -Erwin Landfill is in violation of 15A NCAC 13B .0542 (1)(4) in that leachate has not
been contained on -site. At the time of this inspection, leachate was observed flowing down an erosion rill along the
northern side of the access road that leads to the top of the landfill of the CDLF Area 1. The leachate then crossed
the road into the grassed southern slope of the landfill. A second leachate release was observed flowing from a
drainage pipe into the sediment basin located to the east of the CDLF Area 1. The leachate was observed to be
pooling up in the sediment pond adjacent to the riser pipe.
C. 15A NCAC 13B .0542(c)(2), "The regulated asbestos waste must be covered immediately with soil in a
manner that will not cause airborne conditions and must be disposed of separate and apart from other solid
wastes."
The Harnett County Dunn -Erwin Landfill is in violation of 15 NCAC 13B .0542(c)(2) in that asbestos waste was
exposed and not properly covered within the asbestos waste disposal area. At the time of this inspection, several
bags containing asbestos waste were observed exposed within the asbestos waste disposal area. Large erosion rills
were also identified throughout the asbestos waste disposal area
D. 15A NCAC 13B .0542 (k)(2), "Adequate sediment control measures consisting of vegetative cover, materials,
structures or devices must be utilized to prevent excessive on -site erosion of the C&DLF facility or unit."
The Harnett County Dunn -Erwin Landfill is in violation of 15 NCAC 13B .0542 (k)(2) in that little to no vegetative
cover was identified on the side slopes of CDLF Area 2 and the asbestos waste area. At the time of this inspection,
no vegetative cover was observed on the side slopes of CDLF Area 2. Numerous erosion rills were identified
throughout the side slopes of Area 2. No vegetative cover was observed within the asbestos waste area. Numerous
areas of erosion had exposed asbestos waste and filled a drainage area. Numerous areas with little to no vegetative
cover and erosion rills were observed in several areas of the side slopes of CDLF Area 1.
E. Harnett County Dunn -Erwin Landfill Facility Operations Manual Section 2.2.2 (June 2018), Prohibited
waste include waste exclusions listed in 15A NCAC 13B .0542 as follows: "...Sludge as defined in G.S. 130A-
290(a)(34)." G.S 130A-290 (a)(34) defines sludge as "any solid, semisolid, or liquid waste generated from a
municipal, commercial, institutional or industrial wastewater treatment plant, water supply treatment plant
or air pollution control facility or any other waste having similar characteristics and effects."
The Harnett County Dunn -Erwin Landfill is in violation of the above rule and the Approved Operations Manual in
that sludge from the water treatment plant has been disposed of in the CDLF Area 2. The Division has not approved
the disposal or application of water treatment sludge at the landfill. At the time of this inspection, dried water
treatment sludge was observed to be disposed of along the western side of CDLF Area 2. The sludge was also
observed at the top of CDLF Area 1 and stockpiled across the road from the asbestos waste disposal area. Mr.
Page 2 of 9

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
DP-t a E°°'�m""l W,W Solid Waste Section
Holland stated that the sludge was from the water treatment plant and will be used as cover and to fill areas of
subsidence throughout the landfill. Mr. Holland did not have analytical data for the observed water treatment plant
sludge.
F. 15A NCAC 13B .0566 (4), "Adequate soil cover shall be applied monthly, or when the active area reaches
one acre in size, whichever occurs first.
The exposed waste of the active area of the LCIDLF appeared to be greater than one acre in size at the time of this
inspection. Adequate soil cover had not been applied in several weeks per facility staff. All waste should be
compacted, properly sloped and covered.
G. 15 NCAC 13B .0565 (3) 0) "Excavation, grading and fill material side slopes shall not exceed three to one
(3:1)."
At the time of this inspection, the side slopes of the LCIDLF were greater than 3:1 in several areas. The side slopes
need to be compacted and graded to achieve the 3:1 slope.
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
1. The facility is fenced and is secured by a locking gate when it is not open for operation.
2. The correct signage is at the entrance of the facility listing the facility name, permit number and emergency contact
information as well as materials accepted at the facility.
3. The facility accepts waste Monday through Saturday from 7:30 am until 4:30 pm, with the exception of Wednesday
7:30 am until 12:00 pm.
4. Records were not reviewed onsite during this inspection.
5. The waste type was reviewed at the CDLF and LCIDLF at the time of this inspection. The wastes were mostly
consistent with construction and demolition and land clearing waste. However, there was some unacceptable wastes
observed in both the CDLF and LCIDLF. Numerous tires were identified throughout the working face CDLF Area
2. Additionally, plastic bags, treated lumber, carpet and linoleum were observed within the LCIDLF. The
unacceptable wastes identified within the CDLF and LCIDLF working faces must be removed and properly
disposed of. The presence of the operators at the working face may reduce the unacceptable waste.
6. 15A NCAC 13B .0542 0)(4), "Dust control measures must be implemented." Dust plumes were produced from
vehicles traveling to the CDLF and LCIDLF. The landfills 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.
No measures to reduce or eliminate the dusty conditions were being used at the time of this inspection.
7. The side slopes need mowing and woody vegetation needs to be removed. The lush vegetation on the closed
MSWLF, the inactive CDLF, the asbestos disposal area and the LCID should be mowed as often as necessary
to allow for proper compliance inspection of these areas by site staff and section staff.
8. Windblown waste was observed outside of the CDLF areas at the time of this inspection and should be collected
and returned to the working face prior to close of business daily.
9. Edge of waste markers are installed and being maintained around CDLF Area 1. Edge of waste markers need
to be installed around CDLF Area 2 and the asbestos waste area.
Page 3 of 9

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"—t0E-!�'m"""°"""' Solid Waste Section
10. Water treatment plant sludge was being dumped in the proposed Yard Waste area reportedly for staging for later
use or disposal in the CDLF.
CORRECTIVE ACTION
1. Apply six inches of soil cover to all areas of exposed waste at the CDLF and LCIDLF, including areas along
the service roads and any areas of exposed waste due to erosion.
2. In response to the leachate releases, immediately identify the cause of the releases and take action to stop
the releasees. 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 Amanda
Thompson at Amanda.thompson(&ncdenr.gov and Elizabeth Werner at Elizabeth.werner(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 photograph 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) 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
g. Conclusions and recommendations
3. 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.
4. Necessary measures to control dust emissions must be taken right away.
5. Within 30 days of this report, install edge of waste markers around the CDLF Area 2 and within the
asbestos disposal area.
6. Remove all unacceptable wastes from the CDLF and LCIDLF working faces and properly dispose of the
unacceptable wastes.
Page 4 of 9

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"-t0E'"�m"""°"""' Solid Waste Section
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Amanda
Thompson
Date: 2020.09.02 16:13:54
-04'00'
Amanda Thompson
Environmental Senior Specialist
Regional Representative
Email: [e-mail]
Phone: [phone]
Sent on: X Email Hand delivery US Mail Certified No. 1_1
Copies: Drew Hammonds, Eastern District Supervisor — Solid Waste Section
Jason Watkins, Field Operations Branch Head — Solid Waste Section
Jessica Montie, Compliance Officer — Solid Waste Section
Amanda Freeman, Compliance Officer — Solid Waste Section
Benjamin Jackson, Engineer — Solid Waste Section
Elizabeth Werner, Hydrogeologist — Solid Waste Section
Paula Stewart, Harnett County Manager
Page 5 of 9

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
OepaNnent of Environmental 0ualiry
Solid Waste Section
Digital photographs taken by Amanda Thompson on August 28, 2020.
MR
View of the C&D working face, greater than 0.5 acres.
View of the C&D working face, greater than 0.5 acres
Several tires were identified on the C&D workinv face.
Leachage flowing down an erosion rill in the access road
to Area 1.
Page 6 of 9

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Off;.
View of leachate flowing down the access road to Area 1
Veiw of leachate within the sediment basin, adjacent to
the outfall pipe.
L J .
n
Leachate flowing from drainage pipe into the sediment
basin, located to the east of Area 1.
Exposed asbestos waste.
Page 7 of 9

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Erosion rills and water treatment sludge within Area 2.
Overgrown side slopes and areas of little vegetation and
erosion along the side slopes of Area 1.
Plastic and carpet debris within the LCID.
Erosion within the asbestos waste disposal area.
0
Stock piled water treatment plant sludge.
Near verticle slope of the LCID.
Page 8 of 9

NORTH CAR()LINAD_E Q��
OepaNnent of Environmental 0uali�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 9 of 9