2601-CDLF-1997_INSP_20220118

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: Cumberland
Closed MSWLF X HHW White goods Incin T&P FIRM PERMIT NO.: 2601-MSWLF-1997
2601-CDLF-1997 2601-MSWLF-1980
CDLF X Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: January 18, 2022 Date of Last Inspection: November 10, 2021
FACILITY NAME AND ADDRESS: Cumberland County (Ann Street) Landfill
698 Ann Street Fayetteville, North Carolina GPS COORDINATES: Lat: 35.068936 Long: -78.862257 FACILITY CONTACT NAME AND PHONE NUMBER: Amanda Bader Solid Waste Director O. 910-321-6920 Email: [e-mail] FACILITY CONTACT ADDRESS: Engineering and Infrastructure Department
130 Gillespie Street, Room 214
Fayetteville, NC 28301

PARTICIPANTS: David Powell, Solid Waste Section Amanda Bader, CCSW Mike Renfro, CCSW STATUS OF PERMIT: Active 2601-MSWLF-1997 Permit to Operate for Phase I through IV Cell 10 (Life-Of-Site Permit) – January 3, 2019. In accordance with 130A-294 (a2) this permit is for the life-of-site. Life-of-site ends when the facility reaches its final permitted elevations or by December 17, 2057. The thirty year (30) term of the franchise agreement between the City of Fayetteville and Cumberland
County was executed on October 6, 2008 and ending on October 6, 2038 (DIN 26324). 2601-CDLF-1997 / Closed 2601-MSWLF-1980 Life of Site Permit to Operate 2601-CDLF-1997 – ANN STREET CDLF PHASES I, II, III, IV, V, AND VI A C&D LANDFILL UNIT ON TOP OF A CLOSED MSW LANDFILL and Permit for Closure. POST-CLOSURE CARE REQUIREMENTS FOR THE CLOSED MSWLF PHASE 1 on June 8, 2020; Expires December 29, 2057. (In accordance with 130A-294 (a2) this permit is for the life-of-site. Life-of-site ends when the facility reaches its final permitted elevations or by December 29, 2057.)
PURPOSE OF SITE VISIT: Comprehensive Follow Up Inspection
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 7
STATUS OF PAST NOTED VIOLATIONS: NA

OBSERVED VIOLATIONS: NA
ADDITIONAL COMMENTS
1. David Powell, with the Section, met with Amanda Bader and Mike Renfro with Cumberland County Solid Waste
(CCSW) to follow up on the Cumberland County landfills and the corrective actions mentioned in the previous inspection.

2. County staff indicated during previous visits, when asked about any groundwater issues, that levels for 1, 4 dioxane, and previously dichlorobenzene, were elevated, and they were working with Elizabeth Werner, Hydrogeologist with the Section, and had submitted a plan to monitor. Later during another inspection in November 2021 records reviewing it was discovered that MWGP-5, located south of the CDLF working face and closed MSW, on south side of perimeter road, had very high methane concentrations in recent couple years, and was over the 25% of the LEL for methane. During this inspection visit Ms. Bader called Joan Smyth, with Smith and Gardner (S and G), and she indicated the status and plans moving forward. Also on 1/24/2022, Ms. Smyth sent an email detailing a step by step plan of action the County would like to go. She indicated S and G would be taking over LFG monitoring and compliance, they are already doing GW, reporting for the facility for
Cumberland County. Below is an excerpt of the email she sent, but discussion with Ms. Bader after receiving the email it was determined the first sentence in that email was supposed to be “4th quarter of 2021” not “2022”. Ms. Smyth stated:

As you know, we have also noted the exceedances at GP-5 and now at GP-9 which was not monitored until the 4th quarter of 2022 after we were engaged at the site.
1) S+G is preparing a letter requesting to remove GP-5 from routine monitoring (the well will remain in place), and GP-8, which is located near the property boundary, will be used for future monitoring at the site in this
particular area. Additionally, S+G will request to monitor GP-9 and GP-10 for the first two quarters of 2022 to evaluate landfill gas concentrations in those probes and determine whether longer term monitoring is needed in these probes due to the presence of the Cape Fear River nearby which would prevent any off-site landfill gas
migration. 2) Based on the results from the two quarters, S+G will prepare a comprehensive landfill gas management plan which will include the landfill gas monitoring program for the entire facility as well as plans and information regarding the landfill gas collection system and air permit requirements. We anticipate this plan would be
completed in the third quarter of 2022. Ms. Werner later informed Mr. Powell she agreed with Ms. Smyth. Continue to report to Elizabeth Werner, Hydrogeologist with Section and follow her guidance. Please copy David Powell on these letters/plans. Ms. Smyth submitted a Landfill Gas Monitoring Modification Request Letter on 1/24/2022.

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

Page 3 of 7
3. CDLF/Closed MSW - The County intended to use previously stockpiled shingles for assisting in rebuilding a haul road to Wilkes Road Site. This plan was not approved by Solid Waste Section. Those shingles have now been recycled into asphalt through Barnhill and some have been used in a road for CDLF across closed MSW. During the last inspection some waste was outside EOW markers and needed to be brought back inside EOW. The waste has been put back inside of EOW markers now and soil brought in to repair those areas. Upon review, Ms. Bader had a map showing a road being included in approved plans and using the reasoning for not being allowed to use the shingles at Wilkes road, assumed they would meet those requirements at the CDLF and Closed MSW. She also had SME sample for asbestos before using the waste to construct the road. However, these
plans were not discussed with Section Staff or Permitting. In the future any construction plans should be discussed with Section Permitting before any work is done to ensure compliance. Discussions with Ben Jackson, Section Engineering Project Manager, and Drew Hammonds, Eastern District Supervisor, determined
that several items are required, and copies should be sent to Ben Jackson, as follows:
• Current map of where the road was placed.
• Estimated quantity of material that was placed.
• Statement stating that the waste was inspected by a certified asbestos inspector.
• Statement stating that the waste was placed inside the monitoring area.

Road over closed MSW to CDLF. Shingles should all be inside EOW. Working face out of frame to left.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 7
4. CDLF/Closed MSW – Working face in Phase 6 was small and no unapproved items were visible. Site was muddy from considerable rainfall recently but no ruts on working face. Good job. Access road was passable
with some ruts from traffic, be sure and address when conditions allow.

CDLF working face/over Closed MSW
5. CDLF/Closed MSW – Last visit when leaving the CDLF working face and driving upwards to top of the CDLF older cells, along the roadway and some on top, there was a lot of windblown/exposed waste. Those areas were requested to be fixed. A 50/50 mixture of soil and mulch was used to cover the waste along the roadway and on top of the older cell. Good job. Be sure to establish perennial vegetation, when conditions allow, and monitor
for erosion.

CDLF top of older cell.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 7
Road from working face CDLF to top of older cell. Mulch/soil mixture covering what was exposed waste.
6. CDLF/Closed MSW – Ms. Bader indicated the concrete crushing area would be specifically included in a permit modification application/updated map that will be sent to Section Permitting soon. These type of plans should be discussed with Section Permitting beforehand to work out any issues or requirements that may arise from that activity. It is always easier to discuss and prepare beforehand than afterwards.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 7
7. Active MSW - Currently, the working face is in Cell 10, with cell 9 and 10 being open. Windblown was good and small working face. Daily cover materials include posi-shell, tarps and 50/50 ADC soil/compost mixture.
Working face was not too large during inspection. Additional cover and mowing was needed during last visit, with mowing occurring while onsite. Cover has been added but is a constant struggle. During the application of cover, Mr. Renfro indicated ruts were made and they had to stop work in Cell 9. Since then it has rained and not dried out enough to finish building up and sloping the transition are at bottom of slope from cell 8 into 9/10. However, much progress has been made in these cells. Please continue to build up and slope so that standing water over waste is not an issue, when conditions allow. No water should be standing over waste, such as in photo below, although there were significant rain days before visit, proper cover and sloping would allow for storm water to not be standing over waste nor erode side slopes.

Active MSW Cell 9/10
8. During the last inspection, a new area, in SE corner of the parcel, for taking composted vegetative waste and soil
to mix for 50/50 mix ADC had been established. Soil and the compost are poured onto ground and spread out together. Then loaded up and taken to the landfill working faces. CCSW was instructed to be sure all DEMLR requirements were satisfied. Ms. Bader informed Mr. Powell that this mulch mixing would now be included in the Storm Water Pollution Prevention Plan. Communicate with DEMLR, if not done so, and ensure all requirements have been met involving this site.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 7
9. Although issues have been addressed and corrections onsite made, there are still some needed moving forward to keep the same issues from arising again. Issues such as proper cover and sloping are an ongoing need to be addressed daily, with how the waste structures are built and managed day to day. Keep in mind these issues, and alter the management accordingly to ensure a more appropriate covering, sloping and compacting the working faces and side slopes for new cells and the repairing of older cells. Perennial grasses should be established for erosion control and fighting erosion is a constant need, so be proactive. Additional documents are requested for Section permitting, while DEMLR may have additional requirements to satisfy. Please submit these requested documents in a timely manner for review. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: 910 – 433 – 3350 _
David Powell Environmental Senior Specialist Regional Representative
Sent on: 1/24/2022 X Email Hand delivery US Mail Certified No. [ _]

Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Drew Hammonds, Eastern District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Head – Solid Waste Section Benjamin Jackson, Engineering Project Manager – Solid Waste Section Elizabeth Werner, Hydrogeologist – Solid Waste Section