9228_INSP_20210225

NORTH CAR()LINAD_E Q��
OepaNnent W Envimnmenl.l pu.l�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: WAKE
MSWLF
PERMIT NO.: 9228-CDLF-2001
Closed
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
X
TireT&P
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: February 25, 2021
FACILITY NAME AND ADDRESS:
Red Rock Disposal LLC/Waste Industries, Inc. C&D Landfill
7130 New Landfill Drive
Holly Springs, NC 27540
GPS COORDINATES: Lat.: 35.60580 Long.:-78.90062
FACILITY CONTACT NAME AND PHONE NUMBER:
Donald Plessinger, General Manager
Waste Industries, Inc.
w. 919-557-9583, c. 919-201-1434, f. 919-557-9523
[e-mail]
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS:
Davy Conners, NC DEQ — Solid Waste Section
Andrew Hammonds, NC DEQ — Solid Waste Section
Scott Kamp, Waste Industries, Inc.
STATUS OF PERMIT:
Date of Last Inspection: January 22, 2021
A Permit to Construct Phase 3 and Permit to Operate Phase 1, 3A-1, and 3A-1.2 was issued to Red Rock Disposal, LLC
(9228-CDLF-2001) on October 27, 2020 and will expire on November 19, 2061 or when the facility reaches its final
permitted elevations. The twenty-year term of the franchise agreement with the County of Wake was executed on June 5,
2000 (FID 1226738).
PURPOSE OF SITE VISIT:
Follow up inspection of Red Rock Disposal's self -reported leachate release.
STATUS OF OBSERVED VIOLATIONS) FROM JANUARY 22, 2021 INSPECTION:
Violation: 15A NCAC 13B .0542 (1)(4), Leachate must be contained on -site or treated prior to discharge. An NPDES
permit may be required prior to the discharge of leachate to surface waters.
Status: Unresolved. Red Rock Disposal, LLC remains in violation of 15A NCAC 13B .0542 (l)(4) in that, during the
February 25, 2021 inspection, the leachate release at the toe of the south slope was still ongoing and the corrective actions
(listed below) had not been fully completed. Red Rock Disposal has been pumping and hauling leachate mixed with surface
water from the pond to Sampson County Wastewater Treatment Facility and Lumberton Wastewater Treatment Facility.
Red Rock Disposal has also been pumping and hauling leachate from the French Drain Leachate Collection System to
Lumberton Wastewater Treatment Facility, thus reducing the volume of leachate in the French drain and greatly slowing
the flow of the leachate release (Figure 1). Additionally, the pipe fitting that had been leaking leachate during the January
20, 2021 inspection, had not been repaired (Figure 2).
Page 1 of 6

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
History: On Wednesday, January 20, 2021, Joan Smyth with Smith + Gardner, Inc, on behalf of Red Rock Disposal, LLC,
notified the Section of a leachate release at Red Rock Disposal, LLC that was occurring along the south side of the CDLF.
According to Ms. Smyth, the leachate levels in the French drain system are checked daily, and that morning during the
check staff discovered leachate flowing from the toe of the slope. Red Rock Disposal staff followed the flow of the leachate
to the sediment basin. Red Rock Disposal responded to the leachate release by plugging the outflow pipe of the sediment
basin (Figure 3). On Friday, January 22, 2021, Davy Conners, with the Solid Waste Section, inspected the site. At that
time, leachate releases were still occurring in two locations along the southern slope, one near the west end of the leachate
French drain system and the other a few yards to the east where a pipe fitting was leaking leachate. Smith + Gardner, Inc.,
on behalf of Red Rock Disposal, had taken samples to get approval from a local wastewater treatment facility to receive the
leachate.
OBSERVED VIOLATION(S):
15A NCAC 13B .0542 (f) (1), Except as provided in Subparagraph (3) of this Paragraph, the owners and operators
of all C&DLF units must cover the solid waste with six inches of earthen material when the waste disposal area
exceeds one-half acre and at least once weekly. Cover must be placed at more frequent intervals if necessary to
control disease vectors, fires, odors, blowing litter, and scavenging. A notation of the date and time of the cover
placement must be recorded in the operating record as specified in Paragraph (n) of this Rule.
Red Rock Disposal, LLC is in violation of 15A NCAC 13B.0542 (f) (1) in that during the February 25, 2021 inspection, the
working face was substantially larger than one-half acre in size (Figure 4). Davy Conners and Andrew Hammonds were
present at the end of the operational day, at which time a small area of the working face was being covered, however, the
area of exposed waste still exceeded one-half acre.
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:
The facility is a construction and demolition debris landfill (C&DLF). The facility is permitted to receive construction
and demolition debris, inert debris, land clearing debris, and (used) asphalt from 60 of the counties in NC.
1. As part of the response to the leachate release, Red Rock Disposal, LLC ran a pipe from the French Drain Leachate
Collection System to the top of Phase 1 C of the C&DLF (Figure 5) and dug two trenches through the intermediate
cover and into the waste in order to pump leachate from the French drain back into the landfill (Figure 6). This
activity has not been approved by the Solid Waste Section.
2. While the Section understands the temporary attempt to manage leachate in this manner, the above action
taken by facility staff should not be considered as a permanent solution to the leachate management issues
at this facility. Any further actions to address leachate at this facility shall be discussed and approved prior
to implementation as noted below.
3. During the inspection, two areas with deep erosion rills were observed on the side slopes of the C&DLF (Figure
7). These areas must be to be repaired to prevent further erosion.
4. The top and side slopes of Phase 3A-1 had recently been covered with soil and seeded; however, some areas of
the top had exposed waste (Figure 8) through the cover. Waste must be adequately covered with earthen
material.
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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
CORRECTIVE ACTIONS:
1. Leachate Release — Corrective Action Requirements
a. Continue to take necessary actions to stop the flow of the leachate releases. Actions include, but are not
limited to, pumping and hauling the leachate from the French drain system and plugging the area of the release
with compacted soil. Continue to monitor the levels of the impacted sediment basin and pump and haul as
needed to contain the leachate. Additionally, make repairs to the pipe fitting to stop the flow of leachate in
that location. Notify Davy Conners, davis.conners(&ncdenr.gov, as soon as the leachate release has been
completely stopped.
b. Soil samples and water samples (if applicable) must be taken according to the Sampling Requirements listed
below in Corrective Action 2. Submit the sampling plan and results to Ervin Lane, Hydrogeologist,
ervin.lanenncdenr.gov, 919-707-8288 and Davy Conners, Environmental Senior Specialist,
davis.connerskricderingov, 919-707-8290. Samples must be taken in all areas that have been impacted by
leachate that are outside of the landfill footprint, including any ditches and sediment basins where leachate
has been. If leachate has impacted anywhere downstream of sediment basin, water samples of the stream
will also be required.
c. Determine the underlying cause(s) of the leachate releases and make any necessary repairs to resolve the
cause(s).
d. Submit an updated Operations Plan to include a Leachate Management Plan detailing Red Rock Disposal,
LLC facility's long-term plan to control leachate at the facility. The plan shall contain contingencies for wet
weather and months when temperature does not allow for the distribution of leachate back onto the landfill.
The plan must be submitted to Davy Conners, davis.connersnncdenr.gov, for Section approval.
2. Leachate Release — Sampling Requirements
a. Within 30 days of the leachate release being stopped, submit a Sampling Plan for Section approval prior
to sampling. The proposed plan shall be submitted in electronic format sent via email to Ervin Lane at
ervin.lanekncdenr.gov and Davy Conners at davis.connerskncdenr.gov and must meet the following
requirements:
• Include a map/aerial photo depicting area of impact and proposed sampling locations.
• Provide a description of the proposed sampling methodology.
• Describe proposed subsurface soil sampling and surface water sampling (if applicable) at specific
locations, including background soil and upstream water locations, to evaluate the extent of the
potential environmental impacts from the release(s) at the facility.
i. Subsurface soil samples shall be collected between one to two feet below ground surface.
ii. Discrete soil samples shall be collected. Composite samples will not be accepted.
iii. All soil and surface water samples shall be analyzed by a NC certified laboratory for 40 CFR
Part 258 Appendix I parameters (VOCs and Total Metals), total phosphorus, sulfate, nitrate,
and pH.
b. After obtaining Solid Waste Section approval of the sampling plan, the plan shall be implemented within
seven days. Within 10 days after the analytical results are received from the laboratory, please submit
documentation regarding the sampling event which should include the following:
• A summary of the leachate release, actions taken to address the release, and the release assessment.
• A map/aerial photo depicting the sampling locations.
• A table of the surface water analytical results compared to the NCDWR Surface Water Quality
Standards & Protective Values.
• 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.
• The associated laboratory reports from the NC certified laboratory including the chain of custody and
QA/QC results.
• The sampling methodology, if different from the proposed plan.
• Conclusions and recommendation.
Page 3 of 6

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"' t0E'"�m"""°"""' Solid Waste Section
3. Immediately cover the working face of the C&DLF with six inches of earthen material. Going forward, cover
the working face with six inches of earthen material when the waste disposal area exceeds one-half acre and at
least once weekly.
4. Immediately schedule a meeting with Section staff to discuss the temporary pumping of leachate and other
interim measures to ensure compliance, as well as a more permanent solution to the ongoing leachate issues at
this facility. Scheduling of this meeting should be arranged through Sherri Stanley, Permitting Branch
Supervisor, 919-707-8235, Sherri. Stanleykncdenr.gov.
Photos taken during the inspection can be found in Attachment 1. Please contact me if you have any questions or concerns
regarding this inspection report.
Davy
Conners
Digitally signed
by Davy Conners
Date: 2021.03.05
13:35:05-05'00'
Davy Conners
Environmental Senior Specialist
Regional Representative
Phone: [phone] (o)-, [phone] (c)
Sent on: March 5, 2021 x Email Hand delivery US Mail Certified No.
Copies: Ed Mussler, Solid Waste Section Chief
Jason Watkins, Field Operations Branch Head
Sherri Stanley, Permitting Branch Head
Adam Ulishney, Environmental Compliance Branch Head
Andrew Hammonds, Eastern District Supervisor
Diana Felix, Permitting Engineer
Ervin Lane, Hydrogeologist
Bryan Wuester, GFL Environmental
Joan Smyth, Smith Gardner
Stacy Smith, Smith Gardner
Page 4 of 6

FACILITY COMPLIANCE INSPECTION REPORT
��n1��;poii�
D_E Q�� Division of Waste Management
OepaNmen iEnvironmental0ualiry
Solid Waste Section
Attachment 1: Inspection Photos
Taken by Davy Conners on February 25, 2021
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v.
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Fi ure 1: Leachate release flowin from toe of slo e.
Figure 2: Leachate release from pipe fitting.
PI
Figure 3: Outflow pipe of effected sediment basin
Figure 4: Working face viewed from on top of the closed
plugged.
C&DLF.
Page 5 of 6

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Figure 5: Pipe running across landfill to pump Figure 6: End of pipe pumping leachate into trench
leachate from French drain to tot) of C&DLF. dui in C&DLF.
Figure 7: Erosion rills on C&DLF.
Figure 8: Exposed waste in Phase 3A-1 C&DLF.
Page 6 of 6