1304_INSP_20201119

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: CABARRUS
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 1304-MSWLF-1992
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 11/19/20 Date of Last Inspection: 3/11/20
FACILITY NAME AND ADDRESS: BFI-Charlotte Motor Speedway Landfill V 5105 Morehead Road Concord, North Carolina 28027 GPS COORDINATES (decimal degrees): Lat.: 35.35196 Long.: -80.66805 FACILITY CONTACT NAME AND PHONE NUMBER: Name: Rob LaTourette, General Manager – Republic Services, Inc. Telephone: [phone] Email address: [e-mail] FACILITY CONTACT ADDRESS:
Same as above

PARTICIPANTS: Rob LaTourette, General Manager – Republic Services, Inc. Mike Gurley, Environmental Manager – Republic Services, Inc. Tim Ginn, General Manager Trainee – Republic Services, Inc. Teresa Bradford, DEQ – Solid Waste Section
STATUS OF PERMIT:
A modification to the Permit to Construct Phase 3, Cell 2M and the Permit to Operate Phases 1-3 was issued to BFI Waste Systems of North America, LLC, a wholly owned subsidiary of Republic Services, Inc. on September 14, 2020. The Permit shall expire on March 6, 2052. PURPOSE OF SITE VISIT: Comprehensive Inspection/Odor Investigation STATUS OF PAST NOTED VIOLATIONS: None
OBSERVED VIOLATIONS: A. 15A North Carolina Administrative Code 13B .1626(2)(a) states, “Except as provided in Sub-item (b) of this item, the owner or operators of all MSWLF units must cover disposed 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.” 15A North Carolina Administrative Code 13B .0203(d) states, “By receiving solid waste at a permitted facility, the
permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the condition of the permit.”

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Permit to Operate No. 1304-MSWLF-1992, Attachment 1, Part I, General Permit Condition Number 6 states, “Construction and operation of this solid waste management facility must be in accordance with the Solid Waste
Management Rules, 15A NCAC 13B, Article 9 of the Chapter 130A of the North Carolina General Statutes (NCGS 130A-290, et seq.), the conditions contained in this permit; and the approved plan. Should the approved plan and the rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed by permit condition. Failure to comply may result in compliance action or permit revocation.”
• The approved Operation Plan (Doc. ID. No. 1285996) is included in the List of Documents for the
Approved Plan. Section 1.3.2 “Cover Requirements” of the approved Operation Plan states in part, “At the end of each operating day, the Owner shall cover disposed solid waste with a minimum 6 inches of earthen material to control disease vectors, fires, odors, blowing litter, and scavenging. However, the Owner may also choose to use alternative daily cover.” During the inspection inadequate cover was observed to the west of the working face on Phase 3, Cell 2J. Therefore, BFI Waste Systems of North America, LLC, a wholly owned subsidiary of Republic Services, Inc., is in violation of 15A NCAC 13B .1626(2)(a) and 15A NCAC 13B .0203(d). To achieve compliance, within 10-days of receipt of this inspection report, all waste within the landfill must be covered with a minimum of six inches of earthen material or an approved alternative cover material at the conclusion
of each operating day.
11/19/20: View of inadequate cover and exposed waste on Phase 3, Cell 2J.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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11/19/20: View of inadequate cover and exposed waste on Phase 3, Cell 2J.

B. 15A North Carolina Administrative Code 13B .1626(11)(c) states: “Methods such as fencing and diking shall be
provided within the area to confine solid waste subject to be blown by the wind. At the conclusion of each day of operation, all windblown material resulting from the operation shall be collected and returned to the area by the owner or operator.”
15A North Carolina Administrative Code 13B .0203(d) states, “By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the condition
of the permit.” Permit to Operate No. 1304-MSWLF-1992, Attachment 1, Part I, General Permit Condition Number 6 states, “Construction and operation of this solid waste management facility must be in accordance with the Solid Waste Management Rules, 15A NCAC 13B, Article 9 of the Chapter 130A of the North Carolina General Statutes (NCGS 130A-290, et seq.), the conditions contained in this permit; and the approved plan. Should the approved plan and the rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed by permit condition. Failure to comply may result in compliance action or permit revocation.”
• The approved Operation Plan (Doc. ID. No. 1285996) is included in the List of Documents for the Approved Plan. Section 2.3 “Dust, Litter, Odors and Vectors” of the approved Operations plan states in part, “At the conclusion of each day of operation, all windblown material resulting from the operation shall be collected and returned to the area by the operations team.” During the inspection, an accumulation of windblown waste was observed on the southern side slope of Phase 3, Cell 2J. Therefore, BFI Waste Systems of North America, LLC, a wholly owned subsidiary of Republic Services, Inc., is in violation of 15A NCAC 13B .1626(11)(c) and 15A NCAC 13B .0203(d). To achieve compliance, within 10-days of receipt of this inspection report, all windblown waste must be collected and returned to the working face at the end of each operational day.

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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11/19/20: View of windblown waste on southern side slope of Phase 3, Cell 2J.

ADDITIONAL COMMENTS 1. The modification to the Permit issued September 14, 2020 approved the operations of Phase 3, Cell 2K.
2. The facility consists of a MSWLF and a drop-off convenience area for residential waste.
3. The facility is permitted to receive solid waste generated from within the City of Concord, Cabarrus County, the State of North Carolina and the following counties in the State of South Carolina: Cherokee, York, Lancaster, Chesterfield and Chester.
4. Proper signage was observed at the entrance of the facility. 5. A gate is provided at the entrance of the facility to prevent unauthorized access. 6. The inspection was conducted in response to odor complaints received from two separate parties; one in October 2020 and two in November 2020. An odor investigation of the surrounding area was conducted along with this inspection. A faint garbage odor was detected in a residential area approximately 1,000 feet from the active working area of the landfill (Phase 3, Cell 2K). No other odors associated with landfill activities were detected in any other locations. The odor complaints were discussed with Mr. LaTourette and Mr. Gurley. Operations Inspection of the MSWLF: 7. Two working faces were observed during the inspection. The tipper was being utilized in Phase 3, Cell 2J and a fluff layer was being placed in Phase 3, Cell 2K.
8. No unacceptable waste was observed. 9. The facility is permitted to use automobile shredder fluff mixed with soil, petroleum contaminated soil, tarps and foundry sand as alternative cover material.
10. Edge of waste markers were being maintained. 11. Access roads were well maintained.
Records Review: 12. Reviewed the training records, random inspection records (4 regular waste inspections and 1 special waste inspection per day), quarterly methane monitoring records and the April 2020 groundwater, surface water and leachate monitoring report.
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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13. The leachate line jet cleaning and video inspection of Phase 3, Cell 2K was conducted on September 28, 2020. 14. Certified Manager of Landfill Operations Certifications:
• George Spry, Sr. (expires 7/28/2021)
• Mike Gurley (expires 2/11/2022)
• Anthony Reiss (expires 3/9/2022) 15. Certified Landfill Operations Specialist Certifications:
• Kevin Dennis (expires 4/16/2021)
• George Spry, Jr. (expires 5/16/2021)
• James Drye (expires 10/19/2021)
• James Jacobs (expires 10/19/2021)
• Terry Thomas (expires 12/6/2021)
• Darrail Lovely (expires 3/22/2022)
• James Talley (expires 5/30/2022)
• Christopher Strawbridge (expires 5/30/2022)
• Dale Shepherd (expires 4/15/2023)
• Charles Sparks (expires 4/19/2023)
• Michael Earnhardt (expires 4/19/2023) Please contact me if you have any questions or concerns regarding this inspection report.

________________________________________ Phone: [phone] Teresa N. Bradford Environmental Senior Specialist Regional Representative
Sent on: 12/4/20 X Email Hand delivery US Mail Certified No. [ _]
Copies: Deb Aja, Western District Supervisor – Solid Waste Section Mike Gurley, Environmental Engineer – Solid Waste Section