1306_INSP_20201105

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID YW Transfer Compost X SLAS COUNTY: CABARRUS
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 1306-CDLF-2000
CDLF X Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 11/5/20 Date of Last Inspection: 1/16/20
FACILITY NAME AND ADDRESS: Greenway Waste Solutions of Harrisburg, LLC. (Formerly Highway 49 C&D Landfill Inc.) 2105 Speedrail Drive Harrisburg, North Carolina 28025 GPS COORDINATES (decimal degrees): Lat.: 35.33811 Long.: -80.61046 FACILITY CONTACT NAME AND PHONE NUMBER:
Name: John Brown, Chief Operating Officer – Griffin Brothers Companies Telephone: [phone]
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
19109 West Catawba Avenue, Suite 110 Cornelius, North Carolina 28031
PARTICIPANTS: Andy Burris, Landfill Manager – Greenway Waste Solution of Harrisburg, LLC Brandt Kayser, Environmental Compliance Officer – Griffin Brothers Companies Teresa Bradford, DEQ – Solid Waste Section
STATUS OF PERMIT:
The Permit to Construct the Phase 1 Expansion and the Permit to Operate the Construction and Demolition Landfill -Existing Phases 1-3, Construction and Demolition Treatment and Processing Facility and Type 1 Composting Facility was issued on July 1, 2011. The Permit to Operate expired on July 1, 2016. Permit information has been received by
the Solid Waste Section - Permitting Branch and is under review.

PURPOSE OF SITE VISIT: Operational Inspection/Temporary Disaster Debris Site Evaluation
STATUS OF PAST NOTED VIOLATIONS: None
OBSERVED VIOLATIONS: A. 15A NCAC 13B .0544 (d)(1) states, “Owners and operators of all C&DLF units must ensure that: (A) the concentration of methane gas or other explosive gases generated by the facility does not exceed 25 percent of the
lower explosive limit in on-site facility structures (excluding gas control or recovery system components); (B) the concentration of methane gas or other explosive gases does not exceed the lower explosive limit for methane or other explosive gases at the facility property boundary; and (C) the facility does not release methane gas or other explosive gases in any concentration that can be detected in offsite structures.”

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Greenway Waste Solutions of Harrisburg, LLC is in violation of 15A NCAC 13B .0544(d)(1) in that landfill gas exceedances were detected in facility boundary wells during the February 4, 2020, March 6, 2020, April 1, 2020, May 1, 2020, June 30, 2020, July 20, 2020, August 18, 2020 and September 3, 2020 landfill gas monitoring events. Although
corrective measures have been in progress (see historical information in Additional Comment #6), these measures have been unsuccessful in achieving compliance with this rule.
To achieve compliance, Greenway Solutions of Harrisburg, LLC must immediately take all necessary steps to ensure protection of human health due to the continued exceedance of landfill gas noted at the site, including but not limited to the following: 1. Within 10 days of receipt of this inspection report, contact Perry Sugg, Hydrogeologist, for instructions on additional corrective actions, to include but not limited to, investigating the potential migration of gas onto
adjacent properties. If it is determined that gas has migrated to adjacent properties, a detailed description of both short and long term corrective actions necessary to mitigate risk to public health must be provided. 2. The results of the investigations above may require additional onsite corrective actions to prevent future exceedances and migration of landfill gas beyond the property.
It is highly recommended that Greenway Solutions of Harrisburg, LLC install a combination explosive gas meter (Kiddie KN- COEG- 3 Nighthawk Plug-In or similar) inside all onsite structures including the scale house, gypsum recycling building and work shop for the protection of your employees and facility users. Likewise, Greenway Solutions of Harrisburg, LLC should consider the installation of gas meters in the adjacent properties.
ADDITIONAL COMMENTS
1. The facility consists of a Construction and Demolition Landfill, a Treatment and Processing facility and a Type 1
Composting facility. 2. The facility is permitted to receive solid waste generated within the following counties: Cabarrus, Mecklenburg, Union, Stanly, Iredell and Rowan.
3. The facility is secured by a locked gate at the facility entrance. 4. Access roads are of all-weather construction. 5. On September 14, 2017, the Solid Waste Section - Permitting Branch received a Permit Modification Amendment.
The amendment included an expanded footprint for the existing Phases 1-3 of the CDLF. Please note that no activity (i.e. grading or disposal) can occur in the area of the proposed expanded footprint of the existing Phases 1-3 of the CDLF unless written approval is issued by the Solid Waste Section.
6. Historical Information regarding measures taken to address landfill gas exceedances at the facility:
• On October 17, 2018, Mr. Perry Sugg, Hydrogeologist with the Solid Waste Section (Section), issued a letter to
Greenway Waste Solution, LLC (GWS) entitled “Design Hydrogeologic & Monitoring Reports Technical Review”. In the letter, Mr. Sugg requested that the facility submit a plan to determine the potential for offsite migration due to quarterly methane monitoring regularly detecting methane exceedances in Methane Monitoring
well MMW-1, MMW-2 and MMW-3.
• On August 26, 2019, Civil and Environmental Consultants, Inc (CEC) on behalf of GWS submitted an update to
the Landfill Gas Monitoring Plan. The document was approved by the Section on August 26, 2019.
• On September 9, 2019, CEC on behalf of GWS submitted a Landfill Gas Migration Summary. The document was approved by the Section on September 26, 2019. A summary of methane detections reported as % by volume was included:
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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Three temporary gas probes (GP-1, GP-2 and GP-3) were installed to evaluate the extent of landfill gas migration on May 2, 2019. The gas probes were installed between the property line and the existing methane monitoring wells MMW-1, MMW-2 and MMW-3. The probes were monitored on May 21, 2019, June 12, 2019 and August
13, 2019 showing an increase in methane exceedances.
In order to address the landfill gas migration, the facility proposed to install a landfill gas extraction system consisting of five landfill gas extraction wells (EW-106 through EW-110) around the southwest corner of the existing landfill. At the time of the installation, the extraction wells were to be installed as passive wells and fitted with a “whirlybird” style wind turbines with the ability to convert to active extraction wells with a blower.
Map from the Landfill Gas Migration Summary dated September 9, 2019.
Date MMW-1 MMW-2 MMW-3 4/25/17 17.2% 0.8% 11.0% 6/13/17 17.8% 5.6% 7.1%
9/11/17 18.6% 8.5% 34.3%
12/5/17 26.8% 10.2% 25.6%
3/15/18 27.4% 14.6% 31.5%
6/5/18 35.4% 12.3% 14.3%
9/5/18 22.4% 6.6% 24.6% 12/5/18 13.8% 16.9% 3.7% 2/12/19 24.9% 35.8% 58.7%
5/21/19 28.3% 20.2% 21.1%
6/12/19 12.9% 2.4%% 11.4%
Date GP-1 GP-2 GP-3
5/21/19 0.2% 0.0% 0.0% 6/12/19 19.1% 54.1% 15.4% 8/13/19 40.0% 52.0% 40.6%
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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• Passive landfill gas vents were installed in January 2020.

• Landfill gas monitoring data for 2020:
February 4, 2020 March 6, 2020
Location CH4 (%)
CH4 LEL (%)
H2S
(%)
Location CH4 (%) CH4 LEL (%)
H2S
(%)
MMW-1 18.5 370 0 MMW-1 10.8 216 1
MMW-2 5.5 110 0 MMW-2 19.9 398 1
MMW-3 13.2 264 0 MMW-3 19.0 380 1
GP-1 37.4 748 0 GP-1 33.5 670 1
GP-2 52.0 1,040 0 GP-2 45.4 908 1
GP-3 20.8 416 0 GP-3 24.8 496 1
Scale House 0 0 0
Gypsum Storage 0 0 1
Work Shop 0 0 1

April 1, 2020 May 1, 2020
Location CH4 (%)
CH4 LEL (%)
H2S
(%)
Location CH4 (%)
CH4 LEL (%)
H2S
(%)
MMW-1 17.7 354 0 MMW-1 19.9 398 0
MMW-2 0.7 14 0 MMW-2 1.2 24 0
MMW-3 0.0 0.0 0 MMW-3 0.0 0.0 0
GP-1 29.4 588 0 GP-1 25.0 500 0
GP-2 41.9 838 0 GP-2 39.2 784 0
GP-3 19.0 380 0 GP-3 19.1 382 0

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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June 30, 2020 July 20, 2020
Location CH4 (%)
CH4 LEL (%)
H2S
(%)
Location CH4 (%) CH4 LEL (%)
H2S
(%)
MMW-1 22.3 446 0 MMW-1 19.2 384 4
MMW-2 4.4 88 0 MMW-2 2.9 58 4
MMW-3 17.3 346 0 MMW-3 25.4 508 3
GP-1 27.2 544 0 GP-1 26.9 538 5
GP-2 34.6 692 0 GP-2 33.7 674 4
GP-3 37.0 740 0 GP-3 37.5 750 4
Scale House 0 0 0
Gypsum Storage 0 0 0
Work Shop 0 0 0

August 18, 2020 September 3, 2020 Location CH4 (%)
CH4 LEL (%)
H2S
(%)
Location CH4 (%) CH4 LEL (%)
H2S
(%)
MMW-1 6.7 134 0 MMW-1 3.3 66 0
MMW-2 3.0 60 0 MMW-2 5.9 118 0
MMW-3 34.5 690 0 MMW-3 395 790 0
GP-1 25.8 516 0 GP-1 25.6 512 1
GP-2 31.1 622 0 GP-2 30.1 602 0
GP-3 30.2 604 0 GP-3 20.6 412 0
Scale House 0 0 0
Gypsum
Storage 0 0 0
Work Shop 0 0 0
Operations Inspection of the CDLF: 7. The facility was working in Area 1, Phase 1, Cell 1 during the inspection. 8. No unacceptable waste was observed. 9. The working face appeared to be less than ½ acre in size and was well controlled. 10. Windblown waste was well controlled. 11. Intermediate cover has been placed on the existing Phases 1-3. 12. Good vegetative cover was observed on inactive areas of the landfill. 13. During the inspection, a strong odor attributed to hydrogen sulfide was detected at the original CDLF (Phases 1-3). According to facility staff, the odor was from the passive gas vents that were installed to manage the methane exceedances and groundwater contamination. Following the inspection, several odor complaints from one party have been received. An odor investigation of the surrounding area on November 19, 2020, detected a strong hydrogen sulfide odor offsite in the cul-de-sac of Speedway Rail Court located to the west of the facility. Please contact Perry Sugg to discuss possible corrective actions to minimize odors in conjunction with the corrective actions taken to mitigate the landfill gas exceedances and prevent offsite migration of landfill gases.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Operations Inspection of the Type 1 Compost Facility:
14. No unacceptable waste was observed. 15. The facility had recently ground material. 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: 12/22/20 Email Hand delivery US Mail Certified No. [ _]
Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Adam Ulishney, Environmental Compliance Branch Head – Solid Waste Section Deb Aja, Western District Supervisor – Solid Waste Section Perry Sugg, Hydrogeologist – Solid Waste Section
Larry Frost, Engineering Project Manager – Solid Waste Section Brandt Kayser, P.G., Environmental Compliance Officer – Griffin Brothers Companies Andy Burris, Landfill Manager – Greenway Waste Solutions of Harrisburg, LLC