8302TRANSFER1997_NOV_20210831 Second Attempt

August 31, 2021

CERTIFIED MAIL 7018 0040 0000 4772 0424
RETURN RECEIPT REQUESTED

Attn: Bryant Higgins, Solid Waste Director
Scotland County Annex, 231 E. Cronly St,
P.O. Box 489,
Laurinburg, NC 28353
SUBJECT: Notice of Violation
Compliance Inspection Report
Scotland County Transfer Station
8302T-TRANSFER-1997
Scotland County
Dear Mr. Higgins:
On August 4, 2021, Amanda Thompson and David Powell, representing the State of North Carolina, Division of
Waste Management Solid Waste Section (Section), inspected the above referenced facility for compliance with
North Carolina solid waste statutes and rules. Mr. Lash and yourself were present and represented Scotland
County Solid Waste during this inspection. The following violation(s) were noted:

A.. 15A NCAC 13B .0405(b) - Water that comes into contact with solid waste is leachate and shall be collected from the site for disposal to an approved facility or discharged directly from the site into a
sanitary sewer line. A National Pollutant Discharge Elimination System (NPDES) permit may be required
prior to the discharge of leachate to surface waters, as provided by 40 CFR 258.26 and 258.27, which are incorporated by reference, including subsequent amendments and editions, and may be accessed
at www.ecfr.gov at no cost.
Upon arrival to trailer storage area for TS and tire trailers, it was discovered that a loaded trailer had
been leaking leachate for some time, and was ponded. Several holes in the trailers bottom allowed for
draining of leachate onto ground. Mr. Lash and Mr. Higgins, quickly used 55-gallon plastic drums to capture the leachate. Sampling, excavation and stopping leaks in future were discussed. A soil berm
was also used to prevent leachate runoff.
B. 15A NCAC 13B 0.0405(c) - All vehicles and containers being used for the temporary storage of solid
waste shall be maintained to be leak resistant in accordance with Rule .0105 of this Subchapter, or
shall be stored so that any leachate from the vehicles or containers will be collected to prevent the release of leachate to the environment.

Three areas were leaking a lot of leachate when section staff arrived. Some structural damage was visible underneath the trailer upon inspection.

Scotland County Transfer Station Notice of Violation
August 31, 2021
Page 2 of 3

Based upon the foregoing, Scotland County shall come into compliance by September 13, 2021, with all
requirements of the regulations in 15A NCAC 13B .0405 (b) and (c) by completing the following at the Scotland County Transfer Station:
Corrective Actions
1. Submit a Sampling Plan for Section approval prior to sampling. The proposed plan shall be submitted
in electronic format sent via email and 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; and
• Describe the proposed subsurface soil sampling and surface water sampling (if applicable) at specific
locations, including background soil and upstream water locations. The sampling plan must fully evaluate the extent of the potential environmental impacts from the release(s) at the facility and include,
at a minimum, the following sampling requirements;
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; and
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.

2. After Section approval of the sampling plan, the plan shall be implemented within seven (7) days. Within 10 business days after receiving the analytical results from the laboratory, submit documentation
regarding the sampling event which shall 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 surface water quality standards and
protective values contained in the most current NCDEQ Surface Water Quality Standards Table - download available on the NCDWR Surface Water Standards webpage;
• A table of the subsurface soil analytical results compared to the most current 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; and
• Conclusions and recommendations. 3. Submit the results to William Sugg, Hydrogeologist, 1646 Mail Service Center, Raleigh, NC 27699-1646,
[e-mail] , 919-707-8258, Environmental Senior Specialist, [e-mail],
919-280-5135.

4. Notify David Powell, Environmental Senior Specialist of completion of corrective actions. A follow up
inspection will follow within about 30 days’ receipt of this NOV.
The violation(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.

Scotland County Transfer Station Notice of Violation
August 31, 2021
Page 3 of 3

Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct a follow-up
inspection to verify that the operator has completed the requirements of this Notice of Violation.

If you have any questions, please contact me at (910) 433 - 3350 or e-mail [e-mail].
Sincerely,

David Powell
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section
Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Chris Hollinger, Compliance Officer – Solid Waste Section
Amanda Thompson, Environmental Specialist – Solid Waste Section