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HomeMy WebLinkAbout6403_INSP_20200709NORTH CAROLINAD_E Q�� FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section UNIT TYPE: Lined LCID YW X Transfer Compost SLAS COUNTY: Nash MSWLF PERMIT NO.: 6401-MSWLF-1983 Closed X HHW white X Incin T&P FIRM MSWLF goods 6401-CD LF-1999 6403-CD LF-2000 DS64-006 FILE TYPE: COMPLIANCE CULT: X I Tire T&P / X Tire Industrial DEMO SD lF Collection Monofill Landfill Date of Site Inspection: July 9, 2020 Date of Last Inspection: February 11, 2020 FACILITY NAME AND ADDRESS: Nash County C&D Landfill SR 1425 3057 Duke Rd. Nashville, NC 27856 GPS COORDINATES: N:36.05918 ° E: - 78.00552 ° FACILITY CONTACT NAME AND PHONE NUMBER - Name: Ben Barnes and Matthew Richardson Telephone: 252-459-9823, 252-459-9899 (Barnes cell 252-904-3396) Email address: solidwaste(a)nashcountync.gov; Matthew.Richardson(dr ashcountync.gov FACILITY CONTACT ADDRESS: Nash County Solid Waste P.O. Box 849 Nashville, NC 2 78 56 PARTICIPANTS: Davy Conners, NC DEQ Andrew Hammonds, NC DEQ Ben Barnes, Nash County Craig Fortner, Garrett & Moore, Inc. STATUS OF PERMIT: 6401-MSWLF-1983 (Closed): The MSWLF ceased acceptingwaste duringthe summer of 1998, closure was documented in a CQAR prepared by GEI Consultants and dated December 1998. 6401-CDLF-1999 (Closed): Located on top of the closed MSWLF landfill (6401-MSWLF-1983), construction and demolition waste was accepted until 2000, final closure was documented in a CQAR preparedby GEI Consultants and dated March 2000. 6403-CDFL-2000: Permit to Construct Phases 5-9 and Permit to Operate Phases 1-4 was issued October 24, 2018, and the estimated life of the landfill is approximately through 2053. Temporary Yard Waste Area approval was issued November 16, 2017 and expired on November 16, 2018. As of the July 9, 2020, inspection, this area has been closed out and will no longer be used for yard waste storage. DS64-006: Activated September 13, 2018, must be deactivated by March 13, 2019. As of the July 9, 2020, inspection, this area has been deactivated and will no longer be used as a disaster debris site due to wet conditions. PURPOSE OF SITE VISIT: Follow-up Compliance Inspection Page 1 of 8 D_E FACILITY COMPLIANCE INSPECTION REPORT NORTH CAROLINA Q Division of Waste Management OpnMiml W EnvYanmenbl W.I� Solid Waste Section STATUS OF VIOLATIONS IN THE MARCH 12, 2019 NOTICE OF VIOLATION LETTER AND APRIL 18, 2019 NOTICE OF CONTINUING VIOLATION LETTER: PARTIALLY RESOLVED: 15A NCAC 13B .1627 (d)(1), "Following closure of each MSWLF unit, the owner or operator shall conductpost-closure care... (which) consists of at least the following... (B) Maintaining and operating the leachate collection system in accordance with the requirements in Rules.] 642 and. 1626. " And 15A NCACI3B .1626 (8)(d), "Leachate shall be contained within a lined disposal cell or leachate collection and storage system." Leachate was observed seeping from the same location (northeast corner of the landfill) during the January 23, April 2 and 16, and November 21, 2019 inspections. During the February 11, 2020 inspection, the area of this leachate seep had been regraded and repaired. The area was wetter than the surrounding area and was flowing, however because of rain that day, I could not confirm that it was leachate not surfacewater. During the July 9, 2020 inspection, the area had been repaired again. There was a very small amount of leachate seeping from this area. Additional work may be necessary to stop the leachate seep. Figure 1: Small leachate seep STATUS OF OBSERVED VIOLATIONS NOTED IN JANUARY 23, APRIL 2, AND APRIL 16, 2019 INSPECTION REPORTS: PARTIALLY RESOLVED: 15A NCAC 13B .1627 (d)(1), "Following closure of each MSWLF unit, the owner or operator shall conduct post -closure care... (which) consists of at least the following: (A) Maintaining the integrity and effectiveness of any cap system, including making repairs to the cover as necessary to correct the effects of settlemen4 subsidence, erosion or otherevents andpreventing run-on and run-offfrom eroding orotherwise damaging the cap." And 15A NCACI3B .1626 (8)(b), "Surface water shall not be impounded over or in waste" Page 2 of 8 D_E FACILITY COMPLIANCE INSPECTION REPORT NORTH CAROLINA Q Division of Waste Management YePeNn.M W Envimnmenbl W.I� Solid Waste Section The County had installed weep drains along the berms, however there are still some areas of impounding water. Impounding water is likely the cause of leachate releases and seeps on the landfill. Figure 2: Impounded water over waste. STATUS OF OBSERVED VIOLATIONS NOTED IN APRIL 16, 2019 INSPECTION REPORT: 15A NCAC 13B .1629 (c)(3), "Post -closure use of the property shall not disturb the integrity of the cap system, base liner system, or any other components of the containment system, or the function of the monitoring systems unless necessary comply with the requirements in this Section. " a. RESOLVED: People riding ATVs over the landfill have left trails in the cap. The County has put up no trespassing signs directly in the path of the ATV's which has deterred people from riding on the landfill. b. UNRESLOVED: Trees and woody shrubs are growing on landfill, which could disturb the cap. As of the July 9, 2020 inspection, mowing and removal of some woody growth had been completed, however there are some areas that still need to be cleared. 2. UNRESOLVED, SOME PROGRESS MADE: Burned yard waste from the old yard waste area had been piled, compacted, and buried across the service road from Phase 4 of the CDLF (Cells 4A and 4B). The Section approved a plan and extension of the deadline for compliance for July 31, 2019 for "the materials in this stockpile that are substantially free of stumps and/or identifiable wood waste to be used in the planned stabilization of the inactive portions of the operating CDLF. All stumps and land clearing materials larger than can be used for this application, must be treated as yard waste in accordance with Nash County Landfill's Operation Plan, which states that yard waste will be ground, and Nash County Landfill's Permit to Operate which states, `at least 75% by weight of recyclable and recovery material must be removed from the site within one year."' During the July 9, 2020 inspection, some of the material from this area had been removed and used on the CDLF to help establish vegetative growth. However, most of the burned yard waste material remained in place and was Page 3 of 8 D_E FACILITY COMPLIANCE INSPECTION REPORT NORTH CAROLINA Q Division of Waste Management YePeNn.M W Envimnmenbl W.I� Solid Waste Section seeded by the contractor. This area is not approved for disposal. Additionally, during the removal of the material, it was discovered that the burned yard waste is heavily contaminated with non -vegetative waste such as plastics, metals, etc. All the waste needs to be disposed of properly, which might involve screening out the different waste types. Do not place this material in the LCID landfill without first screening out the unacceptable waste. Figure 3: Area of burned yard waste covered in grass. 3. RESOLVED: 15A NCAC 13B .0542 (f)(2) states, "areas which will not have additional waste placed on them for three months or more, but where final termination of disposal operations has not occurred, must be covered and stabilized with vegetative ground cover or other stabilizing material." And 15A NCAC 13B .0542 (k)(3) "Provision for a vegetative ground cover sufficient to restrain erosion must be accomplished as directed by appropriate state or local agency upon completion of any phase of C&DLF development consistent with Rule .0543 (c)(5) of this Section." As of the July 2020 inspection, the County has established a vegetative groundcover on the old CDLF (Phases 1-3). 4. RESOLVED: 15A NCAC 13B .0542 (1)(2) "Surface water must not impound over or in waste." The terracing on the old CDLF (Phase 1-3) had been regraded to shed water. 5. UNRESOLVED: 15A NCAC 13B .0542 (k)(1 and 2) "Adequate sediment control measures consisting of vegetative cover, materials, structures or devices must be utilized to prevent sediment from leaving the C&DLF facility... (and) prevent excessive on -site erosion of the C&DLF facility or unit." During the July 9, 2020 inspection, the new sediment basin still needed to be cleaned out. Additionally, erosion continues to be an issue at the site. Measures such as vegetative cover, materials, etc. still needed to be utilized to prevent onsite erosion and sediment from leaving the facility. Figure 4: New sediment basin needs to be cleaned out. Page 4 of 8 D_E FACILITY COMPLIANCE INSPECTION REPORT NORTH CAROLINA Q Division of Waste Management °°°°�°"aE°"'�"'°""�✓ Solid Waste Section Figure 5: Excessive erosion at the site. 6. RESOLVED: Non -conforming waste, such as treated wood and plastics were observed in the Temporary Yard Waste area. The county is no longer using the temporary yard waste storage area, see item number 7 below. 7. RESOLVED: The temporary yard waste storage area was approved for a one-year time frame on November 16, 2017 (see Laserfiche link for more information). The one-year time frame lapsed on November 17, 2018. As of July 9, 2020, the temporary yard waste storage area had been cleared of all yard waste and regraded and vegetation had been established. Figure 6: Former temporary yard waste storage area has been regraded and vegetation has been established. RESOLVED: Surface water must be controlled to prevent water from ponding around or within waste. Waste must not be placed in standing water. During the February 11, 2020 inspection, water was still observed ponding in and near the temporary yard waste area and there was black organic leachate flowing from the yard waste piles. Additionally, during the November 21, 2019 and February 11, 2020 inspections, water was observed ponding around the temporary disaster debris yard waste area (DS64-006). That water was black with organic leachate. As of the July 9, 2020 inspection, both areas have been closed and are no longer storing waste. Due to the wet nature of the disaster debris location, that site will no longer be able to be used in the future as a disaster debris staging site. The County should consider finding a different staging area for disaster debris. 9. RESOLVED: The Temporary Disaster Debris site (DS64-006) was approved for disaster -associated yard waste and land clearing debris (vegetative waste) ONLY. During the January 23, 2019 inspection, non- conforming waste such as trash bags, plant pots, aluminum cans, tires and lumber were observed within the disaster debris area. During the July 9, 2020 inspection, all waste from DS64-006 had been disposed of Page 5 of 8 D_E FACILITY COMPLIANCE INSPECTION REPORT NORTH CAROLINA Q Division of Waste Management °°°°�°"aE°"'�"'°""�✓ Solid Waste Section 10. RESOLVED: At the time of the April 16, 2019 inspection, the disaster debris waste and non -conforming waste had been compacted and buried. Duringthe February 11, 2020 inspection, the area had notbeenremoved of waste and was starting to grow grass and weeds over the waste. During the July 9, 2020 inspection, all waste from DS64-006 had been disposed of. 11. RESOLVED: Closure of the disaster debris site should be accomplished within six (6) months of initial site approval, which for this site was March 13, 2019. During the July 9, 2020 inspection, all waste in the disaster debris site had been removed, the area had been regraded, and vegetation had been established. Figure 7: Closed disaster debris site. 12. RESOLVED: 15A NCAC 02C .0108(o) states, "Each non -water supply well shall have permanently affixed an identification plate. The identification plate shall be constructed of a durable, waterproof, rustproof metal or other material approved by the Department as equivalent and shall contain the following information: (1) well contractor name and certification number; (2) date well completed; (3) total depth of well; (4) a warning that the well is not for water supply and that the groundwater may contain hazardous materials; (5) depth(s) to the top(s) and bottom(s) of the screen(s); and (6) the well identification number or name assigned by the well owner." Well heads have been labeled with identification tags (Figure 16). 13. RESOLVED: Many of the edge of waste markers were missing on the closed MSWLF but have since been replaced. 14. RESOLVED: At the time of the April 16, 2019 inspection, a berm around CDLF Cell 4A had been cut to allow surface water to drain to the sediment basin. During the November21, 2019 inspection, the berm from Cell A had been repaired and the cell was not in use, however the berm from Cell 4B had been cut into to allow surface water to drain into the sediment basin. During the February 1, 2020 inspection, the berm had been repaired. a. RESOLVED: Any changes to the design or construction of the CDLF must be approved by the Section. b. RESOLVED: 15A NCAC 13B .0542 (1)(4) "Leachate must be contained onsite or treated prior to discharge." STATUS OF ADDITIONAL COMMENTS IN THE FEBRUARY 11. 2020 INSPECTION REPORT: • PARTIALLY RESOLVED: 15A NCAC 13B .1627 (d)(1), "Following closure of each MSWLF unit, the owner or operator shall conductpost-closure care... (which) consists of at least the following... (B) Maintaining and operating the leachate collection system in accordance with the requirements in Rules .1642 and.1626." And 15A NCACI3B .1626 (8)(d), "Leachate shall be contained within a lined disposal cell or leachate collection and storage system. " Page 6 of 8 D_E FACILITY COMPLIANCE INSPECTION REPORT NORTH CAROLINA Q Division of Waste Management °°°°�°"aE°"'�"'°""�✓ Solid Waste Section Leachate was observed on November 21, 2019, flowing near the base of the north slope of the landfill, passed the edge of waste, and into a drainage ditch between the landfill and the temporary vegetative waste area (Figure 17). During the February 11, 2020 inspection, this area had been plugged with soil however there was a liquid flowing next to the plug (Figure 18). Due to rain that day, I could not confirm if this was leachate or surface water. During the July 9, 2020 inspection, this area had been plugged, however a very small amount of leachate was observed flowing from this area. Additional repairs are necessary to resolve this issue. The County should inspect this area frequently to make sure a leachate outbreak does not recur. Figure 8 & 9: Area of small leachate seep needs to be repaired. 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. Page 7 of 8 D_E FACILITY COMPLIANCE INSPECTION REPORT NORTH CAROLINA Q Division of Waste Management °°°°�°"aE°"'�"'°""�✓ Solid Waste Section ADDITIONAL COMMENTS: The Section approved the use of the burned yard waste as a vegetative stabilization layer for the closed portion of the CDLF. However, during the July 9, 2020 inspection, plastic, metal, and other wastes were found co mingled with the burned yard waste that had been used on the CDLF. Removal of this waste is necessary to be in compliance with the rules. Figure 9: Waste comingled with burned yard waste vegetative stabilization layer Please contact me if you have any questions or concerns regarding this inspection report. Digitally signed by Davy Conners \ DN: cn=Davy Conners, o=Division / of Waste Management, ou=Solid Waste Section, email=davis.conners@ncdenr.gov J c=US Date: 2020.09.17 15:36:29 -04'00' Phone: (919)707-8290 Davy Conners Environmental Senior Specialist Regional Representative Sent on: September 17, 2020 X Email Hand delivery US Mail Certified No.Lj Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Page 8 of 8