2906_INSP_20210824

NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
X
I LCID
YW
Transfer
SLAS
COUNTY: Davidson
MSWLF
PERMIT NO.: 2906-MSWLF-2008,
Closed
HHW
X
White
X
Incin
T&P
FIRM
MSWLF
goods
2906-H H W-
FILE TYPE: COMPLIANCE
CDLF
Tire T&P/
X
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: August 24, 2021 Date of Last Inspection: March 11, 2021
FACILITY NAME AND ADDRESS:
Davidson County Integrated Solid Waste Management Facility
220 Davidson County Landfill Road
Lexington, NC 27292
GPS COORDINATES (decimal degrees): Lat: 35.85281' Long:-80.17620'
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Charlie Brushwood
Telephone: [phone]
Email address: charlie.brushwood(a�davidsoncoun . nc.gov
FACILITY CONTACT ADDRESS:
P. O. Box 1067
Lexington, NC 27293-1067
PARTICIPANTS:
Charlie Brushwood — Davidson County Integrated Solid Waste Management
Tim Phelps, Landfill Supervisor — Davidson County Integrated Solid Waste Management
Michelle Burkhart, Finance Specialist — Davidson County Integrated Solid Waste Management
Susan Heim, Environmental Senior Specialist — Solid Waste Section
STATUS OF PERMIT:
2906-MSWLF-1994: Closed
2906-MSWLF-2008: Life of Site Permit Issued 03/12/2018; Expires 12/8/2068.
2906-HHW: Issued 03/12/2018; Expires 05/28/2023.
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
None
OBSERVED VIOLATIONS:
CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(2) states in part, "the owners or
operators of all MSWLF units must cover disposed solid 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. Alternative materials of an alternative thickness (other than at least six inches of earthen
material) may be approved by the Division if the owner or operator demonstrates that the alternative material
and thickness control disease vectors, fires, odors, blowing litter, and scavenging without presenting a threat to
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
human health and the environment, in accordance with 40 CFR Part 258.21. " Davidson County is in violation
of 15A NCAC 13B .1626(2) for failing to cover all disposed waste with either 6" of soil or a tarp at the end
of each operating day.
Photos were provided by Tim Phelps that show the operational area surrounding the working face had
been completely covered on August 30, 2021.
To achieve compliance, Davidson County shall implement operational procedures that ensure all waste is
covered as required at the end of each operating day. These procedures could include such options as
designating a staff person to maintain cover throughout the workday; hiring extra staff to maintain landfill
cover; altering the hours of landfill operation to allow staff additional time to apply the required daily
cover; or having staff work extra hours to apply daily cover prior to closing operations for the day. A
number of other options may be considered and/or adopted by the county as well. Additional inspections
will be conducted to verify that these procedures are in place.
A view of the operations area looking north toward the leachate storage tank. The working face is visible in the
background where the compactor is operating. The previous day's working face can be seen in the foreground.
Portions of the tarp that had been used as cover at the end of the previous workday are visible sticking up amid the
exposed waste.
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NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A view of the open area leading to the working face. Note the waste exposed throughout by vehicles and
equipment.
The operations area surrounding the working face has been covered as required. (Photo provided by T. Phelps
813012021.)
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NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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
1. The facility includes an active MSW landfill, a closed MSW landfill, a closed C&D landfill, a permanent HHW
collection site, a convenience area, an electronics collection area, a scrap tire collection area, and a white goods
collection area. Only aspects of the active landfill and its ancillary operations were inspected.
2. Photos included in this report were taken by Susan Heim on August 24, 2021, unless otherwise noted.
Field Inspection of Phase 2 Landfill Operations:
3. The area surrounding the facility entrance and scale house was observed to be clean and well -maintained.
4. The facility is secured by a combination of fencing and natural terrain. Unauthorized access is prevented by
means of locking gates.
5. Proper signage was observed at the facility entrance. Informational signs printed in two languages are posted as
needed throughout the facility to assist customers.
6. Facility access roadways are of all-weather construction and were found to be in good condition.
7. Litter was being collected on the northeast slope of the inactive Cell 2 during the inspection, and windblown
waste appeared to be well managed throughout the facility.
8. The leachate tank and secondary containment area were inspected and found to be in good condition. The tank
itself appeared to be intact, with no signs of damage or leakage. The secondary containment was clean and dry.
Mr. Phelps confirmed that the leachate level indicator had been repaired and was functioning properly. The
indicator showed that the tank contained 9,000 gallons of leachate at the time of the inspection. A small pile of
debris was observed along the tank access road, and Mr. Phelps directed facility staff to remove it to the
working face for disposal.
9. Drainage ditches had collected sediment during the recent heavy rain events, and Mr. Phelps stated that, as soon
as dry weather arrived, work would begin on clearing the ditches and the sediment basins. Please perform
regular maintenance on the drainage ditches and sediment ponds to ensure they function as designed.
10. Operations were taking place in the southern end of the new Cell 3 a the time of this inspection.
11. The working face was small, and the equipment operator appeared to be compacting the waste thoroughly. No
unacceptable waste was noted in the working face itself.
12. A portion of the area surrounding the working face was partly covered by a tarp, and several tires were noted in
the exposed waste on top of and around the tarp. Mr. Phelps directed the loader operator to remove the tires so
that they could be transported to the tire collection trailers located on the Phase 1 side of the facility. He also
confirmed that the tarped area had been the location of the working face on the previous day.
13. The operations area surrounding the working face was observed to be in poor condition. A 2" rain event had
taken place two days prior to the inspection, so the operational area was still somewhat muddy. Waste had been
churned up from heavy equipment and vehicles maneuvering in the tipping area. Some windblown litter was
also observed. The lack of cover and the excessive amount of exposed waste in the operations area had been an
issue during the previous inspection on March 11, 2021 and was discussed during this inspection as well. Mr.
Phelps stated that the rain has been making it difficult to apply and maintain cover on the slopes and in the
operations area. Ensure that all waste is covered at the end of every operating day, as required by 15A
NCAC 13B .1626(2). (See Observed Violations section of this report for additional information.)
14. The side slopes of the landfill appeared to be in relatively good condition considering the heavy rainfall that had
been occurring over the past month. Although erosion rills were visible on many of the unvegetated slopes, the
rills were shallow, and no exposed waste was evident. During this inspection, an equipment operator was
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
observed to be repairing the berm around the rim on top of the inactive Cell 2 and tracking soil cover over the
rills on the side slopes. Two areas where exposed waste was observed on the slopes were covered by the end of
the operating day, as required, and Mr. Phelps provided photos of those areas following the inspection.
15. Some small trees and woody vegetation were observed in several areas between the toe of the slope and the
perimeter ditch line in the inactive area of Phase 2. Based on the location of edge of waste markers, much of the
woody growth appeared to be occurring within the landfill disposal boundary. Mr. Phelps stated that he had
been planning to remove the larger trees that could not be eliminated with mowing and regular maintenance and
repair the cap as needed. Please ensure that trees and woody vegetation are removed from the landfill cap,
and that any damage to the cap is repaired and re -seeded promptly.
Field Inspection of the Phase 1 Side of the Facility:
16. The inspection on the Phase 1 side of the facility included the electronics, white goods, scrap tire, and HHW
collection areas, along with the residential convenience center.
17. The entire facility was observed to be clean and well maintained. Windblown litter was minimal and well
managed.
18. The residential convenience center is located northwest of the scale house and is staffed during operating hours.
The attendant directs customers and monitors unloading to minimize unacceptable materials and to re -direct
materials that are required to be separated. COVID protocols prohibit facility staff from physically assisting
residents. However, adjustments to the placement and configuration of the drop-off points make unloading
easier for residents to accomplish on their own.
19. The white goods collection facility is located on the western end of the convenience center. It consists of a
storage building and an elevated concrete pad, a portion of which is covered. Residents unload white goods onto
the pad, which is constructed with a height designed for easy access from the back of a private vehicle. A
loading dock is located on the opposite side of the pad. A small excavator and a compactor are maintained in
the white goods area. The compactor is used to bale scrap metal and white goods after refrigerants are extracted
from the units. The excavator allows facility staff to easily load the white goods into the compactor, then load
the bales into a trailer or roll -off container. Bales are then transported to a local metal recycler by county staff.
The white goods collection area appeared to be clean and well organized. No unacceptable wastes were noted.
Several refrigerant -containing units were observed to be stored separately in an upright position and spaced to
avoid damage to the coils that could cause a release of refrigerant.
20. To receive incoming loads of scrap tires, three tire trailers were staged beside the white goods area and another
near the scale house. No tires were observed on the ground and the tire trailer areas were clean and free from
debris.
21. The county's permanent HHW collection program is operated through a contract with Resource Recovery and
Reduction (permit # 3415-HHW). The county opens the HHW collection site to residents on the first Saturday
of every month. Residents are also able to take HHW and electronics directly to the contractor's facility in
Winston-Salem at any time. Program records are maintained at the contractor's offices, and the county receives
a monthly accounting of the materials accepted.
22. The HHW collection area is protected from unauthorized entry by a perimeter fence and secured with locking
gates. The facility was found to be clean, and waste collected at the August HHW event had been properly
packed, labeled, and stored. One of the containers used to solidify latex paint and paint products was observed
to be approximately 1/3 full.
23. Electronics and televisions are collected in a warehouse building located south of the HHW collection facility.
Residents drop materials off in front of a closed overhead door. Throughout the workday, facility staff
periodically pull the electronic waste into the building where it is sorted, packaged, and stored until the county's
electronics recycling contractor loads it onto a trailer and transports it to their facility for additional processing.
The electronics/TV collection building was observed to clean and well -organized.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
Records Review:
24. All required facility records are kept on file in the landfill office and are available for review upon request.
Records were reviewed on the porch outside of the office. And some records were provided via email following
the inspection.
25. Training on aspects of landfill operating procedures, equipment operation and safety, and regulations that
govern solid waste operations is conducted for facility staff monthly. Training records for the period January
2020 through July 2021 were reviewed and verified.
26. In July, the county conducted its annual leachate spill/release emergency drill to ensure preparedness in the
event of such an occurrence. This year's drill was based on the scenario of a structural failure in the leachate
storage tank walls.
27. Leachate tank inspections are conducted weekly, and records of these inspections covering the period from
January through August 2021 were reviewed and confirmed.
28. The county contracts with JetClean America to regularly inspect and clean leachate collection lines at the
facility, as required. The facility operating record indicated that the last video inspection of the leachate
collection system was conducted in 2019, and all leachate lines were cleaned most recently in November 2020.
29. The facility is required to monitor groundwater and surface water and tests leachate semi-annually. The last
monitoring report provided to the Solid Waste Section was for a sampling event which took place September 21
— 23, 2021. A review of the report indicated it covered groundwater monitoring at the active Phase 2 landfill,
the closed unlined Holly Grove Landfill (permit # 2902), the closed C&D landfill, and the closed lined Phase 1
landfill. Based on historical data, the spring sampling event would have taken place in March 2021, and a report
covering that sampling event would have been due within 120 days following it. Mr. Brushwood stated that he
had not received a report for the groundwater monitoring so far in 2021. Please provide a copy of the
groundwater monitoring report covering the spring 2021 sampling by Tuesday, September 7, 2021, to
Susan Heim via email at susan.heim(&ncdenr.gov in order to demonstrate compliance with the
groundwater monitoring requirements specified in 15A NCAC 13B .1633(b).
30. The facility is required to monitor landfill gas quarterly for the closed Phase 1 landfill, the closed C&D landfill,
and the active Phase 2 landfill. Mr. Brushwood had copies of quarterly landfill gas monitoring reports through
June 15, 2020 available for review, and he stated that he had no reports in his files covering landfill gas
monitoring since that time. Please provide copies of the quarterly landfill gas monitoring reports for the
third and fourth quarters of 2020 and the first quarter of 2021 by Tuesday, September 7, 2021 to Susan
Heim via email at susan.heim(&ncdenr.gov in order to demonstrate compliance with the landfill gas
monitoring requirements specified in 15A NCAC 13B .1626(4)(b).
31. Leachate is pumped and hauled from the landfill to the City of Lexington's wastewater treatment plant for
disposal. The facility records the number of truckloads hauled and matches these records with the city's
monthly billing statements. Leachate disposal records for the period January through August 2021 were
reviewed. For the month of January 2021, 16,687 gallons of leachate were hauled from the active Phase 2
landfill and 440,000 gallons were hauled from the closed Phase 1 landfill.
32. A review of MSW tonnage records for the period July 1, 2020 through June 30, 2021, as reported in the FY
2020-21 facility annual report, indicated that the facility accepted a total of 166,162.20 tons of MSW. For this
reporting period, the average monthly tonnage was 13,850. In addition, tonnage reports for July and August
were provided following the inspection via email. For July 2021, the total waste accepted at the facility was
15,287.77 tons; and the total for August 1-24, 2021 was 11,530.38 tons.
33. The county currently contracts with New River Tire Recycling for scrap tire disposal. Tonnage reports for the
scrap tire program indicate 145.83 tons of tires were collected in July 2021, and 126.88 tons have been collected
to date in August 2021. Scrap tire certifications for the current year are maintained at the scale house and are
available for review as required.
34. Davidson County contracts with Rapid Recovery for CFC removal from white goods. Mr. Brushwood stated
that no CFC removal had been performed as yet in the new fiscal year. A review of the report covering
FY2020-21 found that 153.61 tons of white goods and 562.54 tons of scrap metal had been collected at the
facility.
35. E-Cycle Secure continues as the county's recycling/disposal contractor for computer equipment and televisions.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
The county no longer accepts other electronics and electrical devices for recycling. So far in the new fiscal year,
the county has not collected a quantity of electronic scrap that would fill a trailer, so no tonnage figures are
available for the current year. The report covering FY 2020-21 indicated that approximately '/2 ton of electronics
and TVs were accepted at the facility.
36. The facility conducts waste screenings as specified in the approved Operations Manual (revised March 2018),
and screening forms are filed with a copy of the weight ticket that indicates the amount of waste in the load
being screened. Three random waste screening forms each for the months of July and August 2021 were
provided via email following the inspection, as requested. All forms appeared to have been completed properly
and included information about the disposition of all wastes that were identified in the screening process.
37. Current certifications were on file for the following staff members:
• Charlie Brushwood — SWANA Manager of Landfill Operations — expires 7/15/2024;
• Steven Sink — SWANA Manager of Landfill Operations — expires 7/30/2023;
• Tim Phelps — NCSWANA Landfill Operations Specialist — expires 11/12/2022;
• Kevin Bredow — NCSWANA Landfill Operations Specialist — expires 11/12/2022;
• Phillip Atkinson — NCSWANA Landfill Operations Specialist — expires 10/26/2023;
• Kenneth Biggs — NCSWANA Landfill Operations Specialist — expires 10/26/2021.
38. The cover log for the period January 1 through August 23, 2021 was reviewed. The log indicates the use of
tarps and soil in combination to cover on a daily basis. Mr. Brushwood stated that the cover plan, going
forward, would be to apply the required weekly soil cover on Fridays to the entire operating area.
Woody vegetation and trees appear to be growing on the landfill cap inside the liner.
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NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Small erosion rills are visible on the side slopes of the landfill. Facility staff can be seen working to repair the berm on
top of the landfill and track soil onto the areas of the slopes damaged by the heavy rain events.
A view of the HHW collection area with a covered drive -through lane for residents and secure storage
for wastes accepted.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan Heim
DN: cn=Susan Heim, o=Solid
Waste Section, ou=Field
Operations Branch,
email=[e-mail]
,c=US
Date: 2021.08.31 15:48:40
04'00'
Susan Heim
Environmental Senior Specialist
Regional Representative
Phone: [phone]
Sent on: August 31, 2021, to
X
Email
Hand delivery
US Mail
Certified No. [ ]
Charlie Brushwood, Davidson
Co.
Copies: Deb Aja, Western District Supervisor — Solid Waste Section
Perry Sugg, Hydrogeologist — Solid Waste Section
Steven Sink — Davidson County Integrated Solid Waste Management
Tim Phelps — Davidson County Integrated Solid Waste Management
Michelle Burkhart — Davidson County Integrated Solid Waste Management
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