2601CDLF1997_INSP_20201019

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Cumberland
Closed
MSWLF X HHW White
goods Incin T&P FIRM PERMIT NO.: 2601-CDLF-1997
2601-MSWLF-1980
CDLF X Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: October 19, 2020 Date of Last Inspection: January 25, 2018

FACILITY NAME AND ADDRESS: Cumberland County (Ann Street) Landfill
698 Ann Street Fayetteville, North Carolina GPS COORDINATES: N: 35.065222 W: -78.866372 FACILITY CONTACT NAME AND PHONE NUMBER: Amanda Bader Solid Waste Director O. 910-321-6920
Email: [e-mail] FACILITY CONTACT ADDRESS: Engineering and Infrastructure Department
130 Gillespie Street, Room 214
Fayetteville, NC 28301

PARTICIPANTS: David Powell, NC DEQ, Solid Waste Section Amanda Bader, Cumberland County Solid Waste Director
Chad McClean, Cumberland County, Operations Manager Mike Renfrow, Landfill Supervisor Steve Lamb, SCS Engineering STATUS OF PERMIT: Life of Site Permit to Operate 2601-CDLF-1997 – ANN STREET CDLF PHASES I, II, III, IV, V, AND VI A C&D LANDFILL UNIT ON TOP OF A CLOSED MSW LANDFILL and Permit for Closure POST-CLOSURE CARE REQUIREMENTS FOR THE CLOSED MSWLF PHASE 1 on June 8, 2020; Expires December 29, 2057. (In accordance with 130A-294 (a2) this permit is for the life -of-site. Life-of-site ends when the facility reaches its final permitted
elevations or by December 29, 2057.)

PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: NA

OBSERVED VIOLATIONS: 15A NCAC 13B .1627 (d)(1) states that “Following closure of each MSWLF unit, the owner or operator shall conduct post-closure care…. (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 system.”
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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Cumberland County is in violation of 15A NCAC 13B .1627 (d)(1)(A) in that the cap system was being removed down to the waste as you moved into the next phase of the CDLF over the closed MSWLF and cut ditches adjacent to a road that was constructed on the eastern side of the CMSWLF that exposed the buried waste. Corrective Action requirement are outlined in comment section below. Stop removing the cap and ensure any exposed waste is properly covered per
closure conditions and areas stabilized to prevent erosion.
ADDITIONAL COMMENTS
1. David Powell with the Section met with Cumberland County staff to inspect the MSW/CDLF landfill on October 19, 2020. This was a scheduled visit so staff could be onsite, in the future, most inspections will not be planned in advance.

2. Records were reviewed before inspecting working faces. Record reviewed included: Waste cover records, scrap tire certification forms, waste screening reports, environmental monitoring reports for groundwater, White Goods
refrigerant removal forms and receipts, Cumberland County staff weekly safety training attendance records, Asbestos manifest/weight ticket documentation, certified operator certificates, fire occurrence reports and permit.

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.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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3. A convenience site is located beside the scale house, which accepts, scrap tires, scrap metal, recycling of glass, aluminum, electronics and cardboard. Glass has a place outside the building. Scrap tire collection is done by Central Carolina Holdings, in Sanford NC. Tire certifications records were viewed. 3 trailers open, total 5, onsite
for tires. White goods are removed by county staff, Virgilio Serna EPA certification issued 8/14/2020 was viewed, on Wednesdays. A refrigerant company, United Refrigeration, then purchases the recycled refrigerant. Receipts and records of removal were available. They are separated between ones with refrigerant and ones that have it removed have an “X” on them.

4. Cardboard is stored and collected inside big building behind office and beside scale house. Loose cardboard taken to Pratt in Fayetteville, NC, baled cardboard goes to Sonoco also in Fayetteville. Paper is shredded on Tuesdays. Electronics are taken, once palletized, to recycler in Mooresville NC. There are also roll offs for scrap metal,
furniture, some simple C and D, and garbage. The County separates burned items and requires documentation/burn permit that fire is extinguished 11 days or greater and no coals are brought in which may be a hazard. Used oil can be taken here as well and a company named “Noble” removes it.
5. Shingles are stockpiled onsite beyond convenience site. County isn’t taking any more at this time for recycling. They intend to use the stockpiled shingles for assisting in rebuilding a haul road to Wilkes Road Site. This is in
process for approval currently. County has submitted a plan to the Section and having final questions answered before approval. Please continue in getting approval before any work begins. Currently a plan named, “Shingles Plan Ann Street LF_8-31-20_revised 9-11-20.pdf,” is being reviewed for this project.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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6. County staff indicated, when asked about any groundwater issues, that levels for 1, 4 dioxane and dichlorobenzene were elevated, but they were working with Elizabeth Werner and had submitted a plan to monitor.
7. A MOLO course scheduled for County staff next week and landfill course end of that same week or following week. Landfill Operator certifications for county staff expired 10/5/2020. There are some new operators working for the County, although some are still not actively working right now. County is in process of buying new Dozer and they already have new haul trucks. The compactor is down but they have backup equipment. Good job.

Current working face is now in Phase 6 and slope Phase 5, lateral expansion and covering with soil. Closed MSW now is just groundwater and gas monitoring and maintaining the cap. South west from CDLF working face, on the cap of closed MSW, there are some settled areas in which there was small amount of standing water. It had recently rained, but these areas need addressing to allow storm water to shed off cap, not soak into LF, and not cause erosion while doing so. Address ASAP but when weather and conditions allow. Vegetative cover is needed
on areas recently covered with soil. Reference Permit Attachment 3, Part 3, (21) and Permit Attachment 3 (actually #4 page 17) CONDITIONS OF PERMIT FOR CLOSURE, Part 2, 3.

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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Phase 5, working face is to the right at end of road. Current working face on south east corner. Vegetation needs establishment.
Looking ~ southwest at closed MSW with some settled areas need addressing.
8. In order to address the violation noted above regarding the breach of the cap system of the closed MSW landfill by C&D landfill operations, Cumberland County shall undertake the following: a. Immediately cease all interaction with the closed landfill cap system. Any future impacts to the cap must be pre -approved by the Section or it will result in enforcement action that may include additional engineering controls, enhanced monitoring, forced closure of the landfill, and administrative penalties. b. Within 30 days of receipt, submit a written response to the Section detailing at a minimum: the reason why the cap was impacted, and what actions the facility will undertake to ensure compliance with 15A NCAC 13B .1627 (d)(1)(A). Examples of such action may include things such as staff training, policies on grading and waste placement, increased oversight by management, etc.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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9. At this time, the Section is not requiring waste be removed from the area where the cap impacts were reported by the County and observed by Section staff on 10/28/2020. However, because the integrity of the cap has been compromised presently and also potentially due to operations prior to this event, the facility shall be required to install an enhanced capping system to include an geomembrane or similar, over the entirety of the C&D landfill at the time of closure. Cumberland County should move forward with planning and budgeting for such upgrades to previously submitted and approved closure plans, including any required adjustments for financial assurance, etc. Revised closure plans should be submitted for review and approval within 12 months of receipt of this report. 10. Closed MSW on north west side is being mowed currently. Road in fair shape, could use some grading in areas when conditions and weather allow. Dust is not an issue since recent rain.
North east side of closed MSW. North side of closed MSW.
11. MGW7 3476/MW3 was locked but has broken lid. Broken lids, including those with locks, need replacing so that they are secure from unauthorized access and use. Sampling contractor, SCS Engineering, and county staff should check these when sampling for defects, issues, or if something is broken. It’s the permittees
responsibility for compliance of course, but anyone who notices something damage should report it to management so it can be addressed. MW-K was inspected but had no lock. Ms. Bader locked the well before
we left. MW7 was inspected, locked and seemed in good condition, on north side of CDLF/Closed MSW. Reference 15A NCAC 13B .0544 (b)(2) and 15A NCAC 02C .0108 (l)
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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MW3 lid broken at hinge, needs repair.
Unknown well, located South of C and D working face, with a lock but lid is broken and no information of tag. Has this been abandoned or not or is still active and its name is unclear. Please address. 12. After reviewing records, new issues were discussed. Ms. Bader explained that they are having leachate manholes
gassing off. No lateral migration issues. They plan on running a pipe from Cell 8 to 9/10 and then have the ability to clean and capture that gas. It will eventually be piped to a Blower Flare Station. It was mentioned that a new blower/flare project with redundancy, but still using existing skid to Cargill (gas for boiler fuel), will be started soon. Current treatment system and heat exchanger will be kept. Contract with Cargill will expire May 31, 2021.
Please communicate with DWM Engineer before starting these projects to ensure compliance.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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13. North side of Closed MSW was viewed and in good condition.
14. Concrete crushing area doesn’t have a lot of concrete waiting to be crushed. Good job.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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View of CDLF from MSWLF. North east area needs vegetation at bottom of slope.
15. Corrective measures are necessary and should be completed within 30 days’ receipt of this inspection report. Gas and well cap lids need repairing/plate information, areas need vegetation established as weather and conditions allow, continue working with Elizabeth Werner with groundwater sampling issues, and continue with getting approval for removing of shingles to Wilkes road project. Upon follow-up visit, well corrective actions and vegetation issues should be addressed and ready for inspection. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] _ Environmental Senior Specialist Regional Representative

Sent on: 11/24/2020 X Email Hand delivery US Mail Certified No. [ _]
Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Drew Hammonds, Eastern/Western District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Head – Solid Waste Section
Benjamin Jackson, Engineering Project Manager – Solid Waste Section