4302_NOV_20200902

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
September 2, 2020
CERTIFIED MAIL 7018 0040 0000 4771 8834
RETURN RECEIPT REQUESTED
Chad Beane
Harnett County Solid Waste Director
PO Box 2773
Lillington, NC 27546
RE: Notice of Violation
Harnett County Dunn -Erwin Landfill
Permit #s 4302-CDLF-1998, 4302-CDLF-2018, 4302-MSWLF-1988, 4302-LCID-1998
449 Daniels Road
Dunn, NC 28334
Dear Mr. Beane,
On August 28, 2020, Amanda Thompson and Drew Hammonds, representing the State of North
Carolina, Division of Waste Management Solid Waste Section (Section), inspected the above
referenced facility for compliance with North Carolina solid waste statutes and rules. The
following violation(s) were noted:
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 138.0542 (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
is size.
D_EWAj
NORTH CAROLINA
ileparlment o� EnviranmanGl puaiity
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Harnett County Dunn -Erwin Landfill
Notice of Violation
Page 2of6
September 2, 2020
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 138.0542 (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 138 .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 CDLFArea 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
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NORTH GAROIINAD_E QU
)ep.dt tofFmi,Qn.e. 10—Ifty
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Harnett County Dunn -Erwin Landfill
Notice of Violation
Page 3of6
September 2, 2020
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. 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 LCID 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) (j) "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 LCID were greater than 3:1. The side
slopes need to be compacted and graded to achieve the 3:1 slope.
Based upon the foregoing, upon receipt of this Notice of Violations, Harnett County shall come
into compliance with all applicable requirements of the regulations in 15A NCAC 13B and the
Operations Plan by completing the following:
1. Immediately apply six inches of soil cover to all areas of exposed waste, 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
[e-mail] and Elizabeth Werner at
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NORTH GAROIINAD_E QU
)ep.dt tofFmi,Qn.e. 10—Ifty
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Harnett County Dunn -Erwin Landfill
Notice of Violation
Page 4 of 6
September 2, 2020
[e-mail] 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
NORTH GAROIINAD_ E
Dep.dl tofFmirenme. 10—Ifty
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Harnett County Dunn -Erwin Landfill
Notice of Violation
Page 5 of 6
September 2, 2020
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.
All corrective measures must be completed within 30 days' receipt of this notice of violations,
unless otherwise noted. A follow up site inspection will be conducted after 30 days have passed
to ensure that the corrective measures have been completed to bringthis facility into compliance.
The violation(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 such further relief as may be necessary to achieve
compliance with the North Carolina Solid Waste Management Act and Rules.
In addition to the violations noted above, please note that items # 5, 6, 7, and 9 on the inspection
report require additional action on behalf of the facility in the next 30 days to ensure compliance
is maintained at the facility. Should these items not be addressed in that time frame, the facility
will be subject to future enforcement action(s).
Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct
a follow-up inspection to verify that the facility has completed the requirements of this Notice of
Violation.
If you have any questions
[e-mail].
Sincerely,
Digitally signed by
Amanda Thompson
Date: 2020.09.02
16:12:57-04'00'
please contact me at [phone] (office) or
Amanda Thompson
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
D_EW
NORTH CAROLINA Q
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ilupaamu,1 ui En irp 0. 1 quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

Harnett County Dunn -Erwin Landfill
Notice of Violation
Page 6 of 6
September 2, 2020
copies: Jason Watkins, Field Operations Branch Head
Andrew Hammonds, Eastern District Supervisor
Amanda Freeman, Compliance Officer
Jessica Montie, Compliance Officer
Benjamin Jackson, Engineer
Elizabeth Werner, Hydrogeologist
Paula Stewart, Harnett County Manager
D_EW
NORTH CAROLINA Q
Aj
ilupadmu,I ui En iM..0.G1 quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200