2608CDLF1998_INSP_20210323

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 HHW White goods Incin T&P FIRM PERMIT NO.: 2608-CDLF-1998
CDLF X Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: March 23, 2021 Date of Last Inspection: August 27, 2020

FACILITY NAME AND ADDRESS:
Fort Bragg C&D Landfill
Lamont Road, Fort Bragg

GPS COORDINATES: Lat.: 35.145415 Long.: -79.072703

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Shawn C. Hardy, Solid Waste Manager
Telephone: [phone]
Email address: [e-mail]
Fax: [phone]

FACILITY CONTACT ADDRESS:
Department of the Army
Public Works Business Center
2175 Reilly Rd Stop A IMBG-PWE-C (Attn: Shawn C. Hardy)
Fort Bragg, NC 28310

PARTICIPANTS:
David Powell, NC DEQ, Solid Waste Section
Andrew Hammonds, NC DEQ, Solid Waste Section
Sherri Stanley, NC DEQ, Solid Waste Section
Ben Jackson, NC DEQ, Solid Waste Section
Steven Cox, DPW, Engineering
James “Jim” Duncan, DPW, Environmental Compliance Branch
Shawn Hardy, DPW, Environmental Compliance Branch
Baron Feit, DPW, Environmental Compliance Branch
Daniel Messier, DPW, OMD

STATUS OF PERMIT:
PTC Phase II/Closure of Phase I April 28, 2011; PTC Phase II issued March 19, 2012; PTO Phase II/Close Phase I issued
September 22, 2014; PTC Phase III, PTO Phase I & II, permit for Closure Phase I (partial) issued May 10, 2016.

PURPOSE OF SITE VISIT: Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
Permit to Operate Attachment III, Part III #23; RESOLVED - Ft. Bragg has failed to submit an extension request for
closure activities.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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The Section will resolve this issue due to the conversations on closure and onsite meetings, but a timeline for closure
completion should be submitted.

OBSERVED VIOLATIONS: NA

ADDITIONAL COMMENTS

1. The purpose of the inspection was to inspect the CDLF, discuss the findings of the contract work recently completed
to produce the Cap and Closure Landfill Phase II CQA report and to discuss a plan for a path forward that will meet
all closure requirements successfully.

2. Closure of the CLDF was discussed onsite. Phone conversations with Darrell and Rachel, with Sanitec, explained
some issues with closure. Some of those issues were as follows: The previous borings could not be certified. An
additional 90 borings were done, in which 9 had permeability issues. 19 other areas didn’t have the specified cover
thickness; Alternatives were discussed, and possible equivalencies were suggested by Sanitec. Sherri Stanley,
Section Permitting Branch Supervisor, explained that she is unsure if equivalencies can be done on these issues,
such as the requirement for 1.5-foot permeability layer. Permitting staff will need to review the documents that
will be sent soon by Mr. Cox, the rules and discuss before determining if these equivalencies can be accepted.

Please continue to communicate with NCDEQ Permitting staff on these requirements. Contact is Benjamin
Jackson. Contact Information for Section Engineer Project Manager Benjamin Jackson –
[e-mail] / 919 -707 – 8234 office.

3. Steven Cox will send additional documents, (such as AS-Built drawings/maps, Closure CQA plan). Mr. Cox stated
that they would like to work on a “Scope of Work” for fixing the issues mentioned during this onsite meeting with
NCDEQ input to ensure working towards closure.
As stated above, once scope of work has been determined, a realistic timeline of completion should be submitted
to the Section.

4. Continuing with C and D LF closure was discussed. Progress has been made towards this goal. Some drawings were reviewed by Andrew Hammonds and Fort Bragg staff. Currently the CLDF has 2 complete phases but started closing
the facility before beginning in phase 3. An extension request should be submitted in writing to Ben Jackson per
15A NCAC 13B .0543(c)(6) and Permit to Operate Attachment III, Part III #23. This was done for the Transfer Station
but the CDLF needs a request as well. Ft. Bragg shall contact Ben Jackson for all closure QA/QC and report
requirements to avoid violation of 15A NCAC 13B .0543(c)(7): Following closure of each C&DLF unit, the owner or
operator must notify the Division that a certification, signed by the project engineer verifying that closure has been
completed in accordance with the closure plan, has been placed in the operating record. Ft. Bragg also needs to
submit an updated drawing showing the limit of CD waste, all asbestos disposal areas need to be identified on the
CDLF maps, final elevation and the areas of the facility to utilized for recycling purposes. Some of these items were
discussed last onsite meeting. In fact, some of the work has been completed based on onsite conversations, the
documentation and notification need to be submitted to Solid Waste Permitting.
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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5. Section staff, along with onsite staff, walked phase2, phase 3 and along phase 4 area. East side of Phase 2 CDLF has
a swale that needs repair. Discussions onsite were looking at removing this berm, if possible, and permitting
would look into this possibility and make a determination. Currently it is holding water and not fully functioning
as it was designed. Please address this and check all others for similar issues. Water should not be ponded over
waste and this can lead to leachate issues in the future. Repairs and maintenance of the cap should be done during
optimal conditions to avoid further damage.

15A NCAC 13B .0543 (e)(1)(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.

6. Ft. Bragg did not enter into Phase 3 or 4 before deciding to close. Sedimentation pond still looks good.

7. There was an area of the slope on the North side of Phase 2, along the back that had recently sloughed off despite
erosion control measures. Repair was discussed and using sod to replace vegetation instead of trying to seed to
increase probability of the repair holding. Slope should be repaired as soon as possible to prevent additional slope
failure and erosion.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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8. Mr. Jim Duncan/Mr. Steven Cox submitted electronic copies of Cap and Closure Phase 2 Drawings (dated May 2017),
AS-Built Cap and Closure Phase 2 Drawings (dated March 2020), a July 11, 2028 DWM Inspection of the CDLF facility,
a copy of Letter 13: Clay Barrier Summary Letter for Fort Bragg CD Landfill, Phase 2A, dated December 11, 2018, a
copy of Letter 05: Test Fill – Final Report Section 02 66 10 Fort Bragg CD Landfill, Phase 2A, dated February 15, 2018,
and a copy of CDLF Phase 3 construction and Phase 2 closure Technical Provisions, dated January 2016.

9. Corrective measures are necessary as a result of the inspection findings and shall be completed within 30 days’
receipt of this report. Failure to ensure corrective measures are complete may result in further compliance
actions. Please contact me if you have any questions or concerns regarding this inspection report. ________________________________________ Phone: 910 433 - 3350 _ Environmental Senior Specialist Regional Representative
Sent on: 5/27/2021 X Email Hand delivery US Mail Certified No. [ _]
Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Supervisor – Solid Waste Section Benjamin Jackson, Engineering Project Manager – Solid Waste Section James “Jim” Duncan, DPW - Solid Waste and Recycling Section