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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-CDLF-1999
6403-CDLF-2000
6403-LCID-2020
FILE TYPE: COMPLIANCE
CIDIT
X
Tire T&P/
X
Tire
Industrial
DEMO
SDTF
Collection
Monofrll
Landfill
Date of Site Inspection: September 24, 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 °
Date of Last Inspection: July 9, 2020
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(knashcountync.gov; Matthew.Richardson(c-r�,nashcountync.gov
FACILITY CONTACT ADDRESS:
Nash County Solid Waste
P.O. Box 849
Nashville, NC 27856
PARTICIPANTS:
Amanda Thompson, NCDEQ Solid Waste
Davy Conners, NCDEQ Solid Waste
Andrew Hammonds, NC DEQ Solid Waste
STATUS OF PERMIT:
6401-MSWLF-1983 (Closed): The MSWLF ceased accepting waste during the 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 prepared by GEI Consultants and dated
March 2000.
6403-CDFL-2000: Permit to Construct Phases 5-9 and Permit to Operate Phases 1-4 was issued July 13, 2020, and the
estimated life of the landfill is approximately through 2053.
6403-LCID-2020: Permit to Construct and Permit to Operate was issued July 13, 2020, and the Permit to Operate will expire
on July 13, 2025.
PURPOSE OF SITE VISIT:
Follow-up Compliance Inspection
Page 1 of 7
FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
DP8 to E°°'�m"" lW,Ift Solid Waste Section
STATUS OF PAST NOTED AND OBSERVED VIOLATIONS
15A NCACI3B .1626 (8)(b), "Surface water shall not be impounded over or in waste."
UNRESOLVED: The County has installed weep drains along the berms of 6401-MSWLF-1983, however, there are still
some areas of impounding water. The impounding of water on the cap is possibly a contributing factor for the leachate
releases and seeps historically identified at the landfill. The County should properly grade and slope the area to prohibit the
impounding of water over waste.
Figure 1: Impounded water over waste.
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."
UNRESLOVED: Trees and woody shrubs are growing on 6401-MSWLF-1983, which could disturb the cap. The
vegetation on 6401-MSWLF-1983 and 6403-CDLF-2000 (Phases 1 through 3) was overgrown and in need of mowing. The
landfills needs be mowed as often as necessary to prevent the growth of woody deep root penetrating vegetation and to
allow for the proper inspection of these areas by site staff and section staff.
Figure 2: View of overgrown vegetation at the top of the closed MSWLF.
Page 2 of 7
FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"' t0E ! 'm"" lW'Ift Solid Waste Section
§130A 309.05 (c)(1), "Seventy-five percent (75%), by weight or volume, of the recovered material stored at a facility
at the beginning of the calendar year commencing January 1, shall be removed from the facility through sale, use,
or reuse by December 31 of the same year."
And §130A 309.05 (c)(4), "The recovered material shall not contain significant concentrations of foreign constituents
that render it unserviceable or inadequate for sale, or its intended use or reuse."
UNRESOLVED, SOME PROGRESS MADE: Burned yard waste from the old yard waste area had been piled,
compacted, and buried across the service road from 6403-CDLF-2000 (Phase 4). 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 6403-CDLF-
2000 (Phases I through 3). 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 6403-CDLF-2000
(Phases I through 3) to help establish vegetative growth. However, most of the burned yard waste material remained in
place and was 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., and wood waste that was not suitable for the application and should be removed. All the non -vegetative and
non -suitable wood wastes need to be disposed of properly, which may involve screening out the different waste types. Do
not place this material in the LCID landfill without first screening out the unacceptable waste. During the September 24,
2020 inspection, no additional progress was identified within this area.
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."
UNRESOLVED: During the September 24, 2020 inspection, the new sediment basin, located to the north of 6403-CDLF-
2000 (Phase 4), still needed to be cleaned out. Vegetation was identified growing within the first bay of the sediment basin.
The first bay of the sediment basin needs to be cleaned to allow for the sediment basin to function properly. Additionally,
erosion continues to be an issue at the site. Measures such as vegetative cover, including sod if necessary, netting, rip -rap,
etc. should be utilized to prevent onsite erosion and sediment from leaving the facility.
Figure 3: View of vegetation in the first bay of the sediment basin of the active 6403-CDLF-2000 (Phase 4). Sediment basin needs to be cleaned out.
Page 3 of 7
NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl W.I�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Figure 4: Erosion and sedimentation between the haul road and the active 6403-CDLF-2000 (Phase 4).
OBSERVED VIOLATIONS
July 13, 2020 Permit to Operate, Attachment 3, Part IV (54), "Wastes and recyclables must be maintained in
reasonably sized piles with adequate fire breaks and lanes in accordance with approved operational plans and the
pertinent rules."
And §130A 309.05 (c)(1), "Seventy-five percent (75%), by weight or volume, of the recovered material stored at a
facility at the beginning of the calendar year commencing January 1, shall be removed from the facility through sale,
use, or reuse by December 31 of the same year."
The metal recycling pile was observed to be quite large and precariously stacked during the September 24, 2020 inspection
and a safety issue. At least 75% by weight of recyclable and recovery material must be removed from the site once a year.
A non -perforated purple metal drum with a flammable label was observed at the northern end of the metal recycling pile.
The drum should be removed from the waste stream to determine if the drum is in fact empty
Figure 5: Metal recyclables precariously stacked.
Page 4 of 7
NORTH CAR()LINAD_E Q��
OepaNnent of Envieonm.nbl W.I�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Figure 6: Non perforated drum with flammable label.
July 13, 2020 Permit to Operate, Attachment 3, Part IV (55), "Surface water shall be diverted from all operational
and storage areas to prevent standing water in operational areas and under or around storage piles."
During the September 24, 2020 inspection, metal in the white goods and metal recycling area was found to be stored off the
concrete pad and within standing water. Using best management practices, the white goods and metals should be stored
entirely on the concrete pad and the surrounding area should be graded to promote drainage of surface water away from the
concrete pad.
Figure 7: Metal recyclables stored off concrete pad and in surface water.
15A NCAC 13B .0542 (e) (14), "The following wastes must not be disposed of in C&D LF unit ... Yard trash as defined
in G.S. 130A-290 (a)(45)."
And July 13, 2020 Permit to Operate, Attachment 3, Part II (15), "Wastes listed in 15A NCAC 13B .0542 (e) must
not be accepted for disposal including, but not limited to, hazardous waste, municipal solid waste, liquid waste,
commercial and industrial wastes, and yard trash."
During the September 24, 2020, a load of yard trash, including lawn clippings, pinecones and leaves was dumped onto the
working face of 6403-CDLF-2000 (Phase 4). The County was granted a one-time disposal of comingled yard waste/trash
Page 5 of 7
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
matter and storm debris in 6403-CDLF-2000 (Phase 4) on March 18, 2020. The one-time disposal only applied to waste
that was stockpiled in the expired temporary yard waste site and 2019 storm debris.
Figure 8: Yard trash disposed of in the C&D landfall.
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 settlement, subsidence, erosion or
other events and preventing run-on and run-off from eroding or otherwise damaging the cap."
Several areas of erosion rills were identified along the eastern slope of 6401-MSWLF-1983. The erosion rills need to be
repaired, mulched and seeded to reestablish proper vegetative cover.
Figure 9: Erosion on the eastern slope of the closed MSWLF.
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 6 of 7
FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"' t0E ! 'm"""°"""' Solid Waste Section
ADDITIONAL COMMENTS:
1. The monitoring wells checked during this inspection were properly locked and identified. Good job!
2. The previously identified leachate seeps on 6401-MSWLF-1983 appear to have been plugged and graded. Minimal
vegetative cover was identified. The County should inspect these areas frequently to make sure leachate seeps,
outbreaks and erosion do not recur.
3. Edge of waste markers were not visible on the closed and active cells of 6403-CDLF-2000. EOW markers need
to be placed at the closed and active cells of 6403-CDLF-2000 and should be visible.
4. Recommend that you review the sedimentation and erosion control plans for this facility and ensure that approved
measures are constructed properly and in place as required. Basins impacted by excess sediment should be cleaned
out, restored to plan specifications and properly maintained.
5. Vegetation on the closed 6401-MSWLF-1983, 6403-CDLF-2000 (Phases 1 through 3) and perimeter ditches should
be mowed and maintained frequent enough to allow for proper inspection of the cap and for potential leachate seeps
or releases.
6. On July 13, 2020, Nash County received the Permit to Construct and Operate a LCID landfill to manage yard waste.
The County should begin constructing the new LCID landfill (6403-LCID-2020), so that the yard trash can
be properly disposed of or find another approved method to manage this waste until the LCID landfill is
constructed.
7. Corrective measures are necessary at this facility. Measures to bring the facility into compliance must be
completed within 30 days' receipt of this report. The SWS will conduct a follow-up inspection in 30 days to
ensure issues noted in this inspection report have been addressed.
8. Digital photographs were taken during the inspection.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by
Amanda Thompson
Date: 2020.10.20 15:00:41
-04'00'
Amanda Thompson
Environmental Senior Specialist
Regional Representative
Phone: (910) 433-3353
Sent on: October 20, 2020
Email
Hand delivery
X
US Mail
Certified No. 7019 0700
0000 3643 1700
Copies: Jason Watkins, Field Operations Branch Head — Solid Waste Section
Andrew Hammonds, Eastern District Supervisor — Solid Waste Section
Davy Conners, Environmental Senior Specialist — Solid Waste Section
Amanda Freeman, Compliance Officer — Solid Waste Section
Jessica Montie, Environmental Program Consultant
Zee Lamb, Nash County Manager
Page 7 of 7