7304_INSP_20201021

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
Monofill
Landfill
Date of Site Inspection: October 21, 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: August 12, 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
Erik Seibold, Republic Services
Matt Einsmann, Republic Services
STATUS OF PERMIT:
A modification to the Permit to Construct MSWLF Phase 3 and Operate MSWLF Phase 1, 2, and 3 (Calls 5A and 6A)
was issued September 1, 2020, which allowed for an increase in maximum tonnage from the previously permitted 240,900
tons/year to now 780,000 tons/year. 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:
Follow-up compliance inspection and leachate release investigation.
STATUS OF PAST NOTED VIOLATIONS DURING AUGUST 12, 2020 INSPECTION:
A. PARTIALLY RESOLVED:
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 the end of each
operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing
litter, and scavenging."
During the August 12, 2020 inspection, Upper Piedmont Regional Landfill was 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; a large
amount of exposed waste was observed throughout the top tier of the landfill.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
DP-t a E°°'�m""l W,Ift Solid Waste Section
During the October 21, 2020 inspection, most of the landfill, other than the working face, had been covered with
adequate soil, however there were still areas with some exposed waste (Figure 1).
B. RESOLVED:
15A NCAC 13B.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."
During the August 12, 2020 inspection, Upper Piedmont Regional Landfill was found in violation of 15A NCAC
13B .1626 (8)(d) in that leachate had not been contained within the collection system. On August 11, 2020, 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.
On August 28, 2020, Upper Piedmont submitted the Site Sampling Plan to address the remediation of the soils
from the leachate release. The plan was approved by the Solid Waste Section on August 28, 2020.
On October 8, 2020, Upper Piedmont submitted the Leachate Release Abatement Report, documenting sampling
results and corrective actions taken to resolve the above mentioned violation. On October 14, 2020, the Section
sent the Response to the Leachate Release Abatement Report which stated, "Based on the analytical results,
Republic concluded that the August 2020 leachate release has been abated. The Section agrees with the conclusion
based on the report results and current site conditions. Republic will not be required to conduct additional
assessment related to the August 2020 Leachate release at this time."
During the October 21, 2020 inspection, the area of the August 2020 leachate release had been repaired and the
multiple seeps had been plugged. Upper Piedmont had installed rock sumps to catch and pump leachate in that
area (Figures 2 and 3).
These corrective actions resolve the 15A NCAC 13B.1626 (8)(d) violation from August 12, 2020.
NOTICE OF VIOLATION FOR OCTOBER 21, 2020 INSPECTION:
A. 15A NCAC 13B.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. On October 20, 2020, Matt Einsmann notified the Section of a leachate
release that occurred in the leachate containment tanks and secondary containment. According to Matt Einsmann
and Erik Seibold, early morning on Monday October 19, 2020, Upper Piedmont was notified of a leak in their
leachate tanks. When Upper Piedmont Staff arrived on site, Tank A and B were full of leachate and had
overflowed into the secondary containment, which had only approximately 4 inches of freeboard remaining. Two
releases were identified, the first coming from a hole approximately 25 feet above the ground in Tank B, which
due to the static head in the leachate tank, was causing leachate to flow out of the hole beyond the secondary
containment system. The second release came from a leak between the flange and the secondary containment
wall where the leachate inlet pipe enters the leachate storage system. This leak was of the leachate that had
overflowed into the secondary containment not from the inlet pipe itself. Approximately 200 gallons of leachate
were released from both leaks.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"—t0E-!�'m"""°"""' Solid Waste Section
Upper Piedmont responded to the releases by constructing an earthen dam to contain the leachate. The leachate
in the tanks and secondary containment was pumped down over the course of two days. Additionally, the leachate
that had been contained within the earthen dam was pumped. By Tuesday afternoon the leachate levels in Tank
B had been pumped below the holes and they were patched temporarily until they could be repaired (Figure 4).
During the October 21, 2020 inspection, leachate was observed in the following areas: 1. saturating the ground
surrounding the leachate storage system (Figure 5 and 6), 2. in a drainage ditch between the office building and
the tanks (Figure 7), and 3. on the concrete pad next to the leachate storage system (Figure 8). The following
actions had been taken to contain the leachate in these areas, respectively: an earthen dam had been built
surrounding the storage system and the area had been pumped of most of the leachate, an earthen dam had been
built to stop leachate from flowing into a concrete culvert and the area had been pumped of most of the leachate,
and the concrete pad had been pumped of most of the leachate.
On October 22, 2020, Upper Piedmont submitted the Site Sampling Plan. On October 22, 2020, the Section
approved the plan.
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 1A, 2A, 3A, and 4A),
Phase 2 (Cells 1B, 2B, 3B, and 4B) 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 780,000 tons per year.
The following compliance issues were observed during the March 26, 2020 and/or the August 12, 2020 inspections. The
status of these issues listed below is based on the October 21, 2020 inspection.
1. 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. Matting and seeding has taken place and vegetation has started to
grow on most of the landfill. A few areas remain that need to be seeded, however, Erik has hired a contractor to do
this work and it should be finished in a couple of weeks.
2. RESOLVED: Erosion rills were observed on the slopes of the landfill. The erosion rills observed during the
March 26, 2020 and August 12, 2020 inspections have been patched with dirt and seeded with grass.
3. RESOLVED: Large plumes of dust were produced from trucks traveling on the road to the top of and
surrounding the landfill. Dust control measures were in place that sufficiently suppressed dust.
4. UNRESOLVED: Water was observed ponding in small amounts on the top tier of the landfill (Figure 9).
Surface water must be diverted from all operational and storage areas to prevent standing water in operational areas.
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NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
1. Immediately apply six inches of soil cover to all areas of exposed waste, including any areas of exposed
waste due to erosion.
2. Upper Piedmont has submitted the Site Sampling Plan and the Section has approved the plan.
The Site Sampling Plan shall be implemented within seven (7) days after Section approval of the plan.
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;
E The sampling methodology, if different from the proposed plan; and
g. Conclusions and recommendation
Submit the results to Ervin Lane, Hydrogeologist, 1646 Mail Service Center, Raleigh, NC 27699-1646,
[e-mail], 919-707-8288, and Davy Conners, Senior Environmental Specialist,
[e-mail], 919-621-3685.
3. 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
DN: cn=Davy Conners, o=Division of Waste
y iUiJ ��_,.,;:.� Management, oa=Solid Waste Section, Email: [e-mail]
J email=[e-mail], c=US
Date: 2020.10.30 13:37:30 -04'00' Phone: [phone]
Davy Conners
Environmental Senior Specialist
Regional Representative
Sent on: October 30, 2020 X Email Hand delivery US Mail Certified No. !,1
Copies: Ed Mussler, Section Chief
Jason Watkins, Field Operations Branch Head
Andrew Hammonds, Eastern District Supervisor
Ervin Lane, Hydrogeologist
Amanda Thompson, Environmental Senior Specialist
Jessica Monte, Compliance Officer
Amanda Freeman, Compliance Officer
Matt Einsmann, Republic Services
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"—t0E-!�'m""lW'Ift Solid Waste Section
Attachment I: Inspection Photos
Taken by Davy Conners, October 21, 2020
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Figure 1: Exposed waste
Figure 2: Repairs made in area of previous (August 12,
2020) leachate release.
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Figure 3: Rock sumps installed in area of previous
Figure 4: Hole in the leachate tank taped as a temporary
leachate release.
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Figure 5 Leachate release.
Figure 6: Leachate release.
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
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