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HomeMy WebLinkAbout0403_INSP_20220304FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 13 UNIT TYPE: Lined MSWLF X LCID YW Transfer Compost X SLAS COUNTY: ANSON Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 0403-MSWLF-2010 CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: 3/4/22 Date of Last Inspection: 10/22/21 FACILITY NAME AND ADDRESS: Chambers Development MSW Landfill (Anson County Landfill) 375 Dozer Drive Polkton, North Carolina 28135 GPS COORDINATES (decimal degrees): Lat.: 34.9993 Long.: -80.1687 FACILITY CONTACT NAME AND PHONE NUMBER: Name: Tyler Fitzgerald, District Manager Telephone: (704) 694-6900 Email address: tylerf@wasteconnections.com FACILITY CONTACT ADDRESS: Same as Above PARTICIPANTS: Tyler Fitzgerald, District Manager – Waste Connections, Inc. Blake Balogh, Operations Manager – Waste Connection, Inc. Teresa Bradford, NCDE Q – Solid Waste Section Deb Aja, NCDEQ – Solid Waste Section STATUS OF PERMIT: A Life of Site Permit was issued on December 15, 2020. The permit includes the Permit to Construct Phases 3 and 4 and the Permit to Operate Phases 1, 2, and Cell 1A and 2 of Phase 3. Life-of-site end when the facility reaches its final permitted elevations, or not later than December 12, 2060, which is 60 years from the initial operation of the landfill. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: 1. 15A NCAC 13B .1626(1)(b) and 15A NCAC 13B .0203(d). This violation is considered resolved. On January 12, 2021, Civil and Environmental Consultants, Inc. on behalf of Chambers Development, Inc., submitted correspondence entitled “Hazardous Waste Assessment Plan” in response to the Notice of Violation issued on December 15, 2020. The plan was reviewed and subsequently resubmitted on April 16, 2021. The revised plan was approved on April 29, 2021 with the requirement to submit a Water Quality Monitoring Plan addendum. The “Water Quality Monitoring Plan -Addendum #1” for enhanced monitoring for cadmium was approved on May 19, 2021. To date, four leachate sampling events from the Phase 3, Cell 1 Sump have occurred. Cadmium has not been FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 13 detected. Continue sampling as required in the approved “Water Quality Monitoring Plan-Addendum #1. Please note, additional actions may be required if elevated levels of cadmium are detected in future sampling events. 2. 15A NCAC 13B .0203(d) for failing to control odors. Corrective measures in progress. In conjunction with the inspection, an odor investigation was conducted of the area surrounding the landfill. While no landfill odors were detected outside of the facility boundary, additional citizen complaints have been received. In April and May 2021, staff from the Division of Air Quality observed and documented objectionable odors beyond the facility property boundary. The Division of Air Quality requested an Odor Management Plan, which requires the facility to identify all potential sources of odors, controls for emissions from those sources, and an implementation plan with a schedule of activities. The facility’s response to that request has been submitted and is currently under review. Continue to follow all actions required by the Division of Air Quality. Additional measures may be required by the Division of Waste Management-Solid Waste Section as stated in the Notice of Violation issued on April 28, 2021. 3. 15A NCAC 13B .1626(2)(d) for failing to provide no less than one foot of intermediate cover in areas that will not have additional waste placed on them for 12 months or more, but where final termination of disposal operations had not occurred. This violation is considered unresolved. During the inspection, additional soil cover was observed to have been placed in areas of inadequate intermediate cover that was observed during the October 22, 2021 inspection. However, new areas of exposed waste were observed. Please see the Observed Violations section of this report. 4. 15A NCAC 13B .0203(d) for failing to follow 15A NCAC 13B .1626(2)(d) and by failing to apply an additional 6-inch layer of compacted soil whenever an additional lift of waste will not be placed within 30 days as required in the approved operations plan. This violation is considered unresolved. During the inspection, additional soil cover was observed to have been placed in areas of inadequate intermediate cover that was observed during the October 22, 2021 inspection. However, new areas of exposed waste were observed. Please see the Observed Violations section of this report. OBSERVED VIOLATIONS: A. 15A North Carolina Administrative Code 13B .1626(2)(b) states, “Except as provided in Sub-Item (c) of this Item, the owners or operators of all MSWLF units shall 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 prevent the escape of waste and the attraction of vectors and scavenging, and to minimize fires and the generation of odors.” During the inspection, exposed waste was observed on the left side of the haul road leading to the active working area and also to the south of the active working area. Therefore, Chambers Development of North Carolina, Inc., is in violation of 15A NCAC 13B .1626(2)(b) by failing to adequately cover all disposed waste with six inches of earthen material. B. 15A North Carolina Administrative Code 13B .0203(d) states, “By receiving solid waste at a permitted facility, the permittee shall be considered by the Department to have accepted the conditions of the permit and shall comply with the conditions of the permit.” FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 13 Permit to Operate No. 0403-MSWLF-2010, Attachment 1, Part I, General Permit Condition Number 6 states, “Operation of this solid waste management facility shall be in accordance with the Solid Waste Management Rules, 15A NCAC 13B; Article 9 of the Chapter 130A of the North Carolina General Statutes (NCGS 130A- 290, et seq.); the conditions contained in this permit; and the approved plan. Should the approved plan and the rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed by permit condition. Failure to comply may result in compliance action or permit revocation.” The approved Operation Plan (Doc. ID. No. 1086505) is included in the List of Documents for the Approved Plan. Section 5.17.2 “Daily Cover” of the approved Operation Plan states in part, “Daily Cover comprised of 6 inches of compacted soil or other approved alternative material will be placed on the working face and other exposed waste at the end of each operating day. If conditions warrant (such as adverse weather or excessive wind), daily cover will be applied at more frequent intervals. Daily cover will also serve as a firebreak.” During the inspection, exposed waste was observed on the left side of the haul road leading to the active working area and also to the south of the active working area. Therefore, Chambers Development of North Carolina, Inc., is in violation of 15A NCAC 13B .0203(d) by failing to adequately cover all disposed waste with six inches of earthen material. To achieve compliance, all waste must be covered with a minimum of six inches of earthen material or an approved alternative cover material at the conclusion of each operating day. View of exposed waste located to the south of the active working face. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 13 View of exposed waste located to the south of the active working face. View of exposed waste on the haul road leading to the active working face. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 13 C. 15A North Carolina Administrative Code 13B .1626(2)(d) states, “Areas that will not have additional waste placed on them for 12 months or more, but where final termination of disposal operations has not occurred, shall be covered with a no less than one foot of intermediate cover.” During the inspection, exposed waste was observed on portions of the top of Phase 1, in areas that were seeded in December 2021/January 2022 on the southeastern/eastern side slope of Phase 1 and in areas of construction activities associated with the landfill gas extraction wells. Therefore, Chambers Development of North Carolina, Inc. a wholly owned subsidiary of Waste Connections, Inc., is in violation of 15A NCAC 13B .1626(2)(d) by failing to cover all areas of intermediate cover with no less that one foot of cover. D. 15A North Carolina Administrative Code 13B .0203(d) states, “By receiving solid waste at a permitted facility, the permittee shall be considered by the Department to have accepted the conditions of the permit and shall comply with the condition of the permit.” Permit to Operate No. 0403-MSWLF-2010, Attachment 1, Part I, General Permit Condition Number 6 states, “Operation of this solid waste management facility shall be in accordance with the Solid Waste Management Rules, 15A NCAC 13B; Article 9 of the Chapter 130A of the North Carolina General Statutes (NCGS 130A-290, et seq.); the conditions contained in this permit; and the approved plan. Should the approved plan and the rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed by permit condition. Failure to comply may result in compliance action or permit revocation.” The approved Operation Plan (Doc. ID. No. 1086505) is included in the List of Documents for the Approved Plan. Section 5.17.2 “Intermediate Cover” of the approved Operation Plan states in part, “An additional 6-inch layer of compacted soil will be placed whenever an additional lift of waste will not be placed within 30 days. All areas with exposed intermediate cover will be inspected weekly. Additional compacted soil will be placed to repair cracks and erosion as necessary.” During the inspection, exposed waste was observed on portions of the top of Phase 1, in areas that were seeded in December 2021/January 2022 on the southeastern/eastern side slope of Phase 1 and in areas of construction activities associated with the landfill gas extraction wells. Therefore, Chambers Development of North Carolina, Inc., a wholly owned subsidiary of Waste Connections, Inc., is in violation of 15A NCAC 13B .0203(d) by failing to follow 15A NCAC 13B .1626(2)(d) and by failing to apply an additional 6-inch layer of compacted soil will be placed whenever an additional lift of waste will not be placed within 30 days as required in the approved operations plan. To achieve compliance, ensure that all areas that will not have additional waste placed on them for 12 months or more, but where final termination of disposal operations has not occurred is covered with no less than one foot of intermediate cover. Also, the facility shall document when the exposed intermediate cover is inspected weekly as stated in the approved operations plan. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 13 View of inadequate intermediate cover on the top of Phase 1. View of exposed waste in areas seeded on the southwestern side slope of Phase1 of the MSWLF. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 13 View of inadequate intermediate cover on the top of Phase 1. E. 15A North Carolina Administrative Code 13B .1626(11) states, “Windblown waste requirements. Methods such as fencing and diking shall be provided within the area to confine solid waste that is subject to be blown by the wind. At the conclusion of each operating day, all windblown material resulting from the operation shall be collected and disposed of by the owner or operator.” During the inspection, windblown waste was observed in the area seeded on the eastern and southeastern side slope of Phase 1 and Phase 2. Windblown waste was also observed on the western side slope of the landfill. Therefore, Chambers Development of North Carolina, Inc., a wholly owned subsidiary of Waste Connections, Inc., is in violation of 15A NCAC 13B .1626(11) for failing to collect and properly dispose of windblown material at the conclusion of each day of operation. To achieve compliance, collect and properly dispose of windblown material at the conclusion of each day of operation. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 13 View of windblown waste on Phase1 of the MSWLF. View of windblown waste on Phase1 of the MSWLF. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 13 View of windblown waste on western side slope of the landfill. ADDITIONAL COMMENTS 1. The facility consists of a MSWLF and a drop-off convenience area for residential waste. 2. The facility is permitted to receive solid waste generated from within the States of North Carolina and South Carolina, consistent with the local government waste management plan and with the franchise approved by the Anson County Board of Commissioners. The facility must not receive solid waste from transfer stations that accept solid waste generated in states other than North Carolina and South Carolina. 3. Proper signage was observed at the entrance of the facility. Operations Inspection of the MSWLF: 4. Waste was being placed in Phase 2/Phase 3, Cell 1. 5. The facility is permitted to use a tarp, automobile shredder fluff mixed with soil, petroleum contaminated soil and seaboard solids as alternative cover material. 6. The facility utilizes three tippers. 7. No unacceptable waste was observed. 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 10 of 13 8. During the inspection, exposed waste was observed on the left side of the haul road leading to the active working area and also to the south of the active working area. Please see the Observed Violation section of this report. 9. In conjunction with the inspection, an odor investigation was conducted of the area surrounding the landfill. While no landfill odors were detected outside of the facility boundary, additional citizen complaints have been received. 10. Strong landfill gas odors were detected around gas extraction well # 25 which is located on the top of Phase 1. 11. No odors were detected around the solidification pit. 12. Additional soil was observed to have been placed in the northwest corner of Phase 3 near the leachate cleanouts in an area identified via a drone as an area of landfill odors. 13. Strong landfill gas odors were detected around the leachate cleanout on the corner of the northwestern side of Phase 3. Facility staff stated that bolts were tightened on the leachate cleanout after the inspection. 14. Gas extraction well # 36 has been redrilled. 15. Pneumatic pumps with air and condensate lines were installed on 20 gas extraction wells. The work was finished at the end of February. Exposed waste was observed in some areas of the construction activities associated with the landfill gas extraction wells. Please see the Observed Violation section of this report. 16. The gas wellfield is balanced twice per month. 17. Two separate seeding projects occurred on the southeastern/eastern side slope of Phase 1-3 in December 2021 and January 2022. During the inspection, the first area seeded had visible waste and windblown waste. Please see the Observed Violation section of this report. 18. Windblown waste was also observed on the western side slope of the landfill. Please see the Observed Violation section of this report 19. Edge of waste markers were being maintained. 20. Access roads were well maintained. 21. The woody vegetation on Phase 1 of the MSWLF needs to be removed. 22. Leachate recirculation is not being conducted. 23. The leachate storage area consists of two 250,000-gallon leachate storage tanks and a leachate storage basin consisting of an in-ground storage tank constructed of lined cast-in-place concrete. 24. The leachate storage tanks are kept empty and are available as back-up to the leachate storage basin. 25. The leachate storage basin appeared to have an adequate amount of freeboard 26. Following this inspection, on March 9, 2022, a meeting with facility managers was held to discuss the prioritization of tasks, proactive methods and increased efficiencies to ensure compliance in all aspects of landfill operations. Operations Inspection of the Yard Waste Treatment and Processing (Wood Grinding)/Composting Area: 27. Yard waste was observed accumulated at the entrance of the yard waste/composting preventing access. It was discussed with facility staff that proper access needs to be provided to the yard waste area. 28. Take measures to ensure that unacceptable waste is removed from the incoming yard waste upon arrival. 29. The facility is not actively composting at this time. Ground material is used within the landfill. No material is distributed to the public. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 13 View of the entrance to yard waste/compost area. View of unacceptable waste mixed with incoming material. Operations Inspection of the Scrap Tire Collection Area: 30. Tires were being collected in a covered trailer. Operations Inspection of Electronics Collection Area: 31. Electronics were observed to on the ground with varying degrees of damage including broken glass and plastics. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 13 32. The facility staff stated that a new electronic recycling vendor has been acquired. The former electronics recycling vendor allowed the material to be placed into roll off containers. Electronics will now be placed on pallets and shrink wrapped in preparation for removal by the vendor. 33. Please ensure that electronics are managed to minimize damage and creating nuisance conditions. View of damaged electronics in the electronics collection area. Records Review: 34. The permit and operations plan were verified onsite. 35. Random load inspection records were reviewed. The facility conducts 10-15 random load inspections per day. It is recommended that the tonnage be included on the random load inspection form to ensure that 10% of all incoming loads are inspected as required in the approved operations plan. 36. Special waste determination and asbestos protocols were reviewed. A random sampling of waste determination records was reviewed. 37. Quarterly methane monitoring was being conducted as required. Records for sampling events performed on 7/28/21, 10/5/21 and 1/10/22 were reviewed. No exceedances above applicable standards were observed. 38. Semiannual groundwater, surface water and leachate monitoring were verified via the Division Document Database. The 1st semiannual sampling event was performed in April and May 2021. The 2nd semiannual sampling event was performed in October and December 2021. 39. The enhanced leachate monitoring of Phase 3, Cell 1 Sump for cadmium was verified via the Division Document Database. 40. Leachate discharge records were reviewed. The leachate is pumped from the leachate storage basin to the Anson County WWTP via a force main. 514,560 gallons of leachate were discharged in February 2022. 41. A random sampling of scrap tire certifications forms was reviewed. The forms appeared to be properly completed. 42. Certified Manager of Landfill Operations Certifications: • Tyler Fitzgerald (expires 9/10/2022) 43. Certified Landfill Operations Specialist Certifications: • Brian Blalock (expires 8/18/2024) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 13 • Bret Blalock (expires 8/18/204) • Scottie Harrington (expires 8/18/2024) Please contact me if you have any questions or concerns regarding this inspection report. Phone: (704) 235-2160 Teresa N. Bradford Environmental Senior Specialist Regional Representative Sent on: 3/22/22 to Corporation Service Company, Registered Agent Email Hand delivery X US Mail X Certified No. [7018 0360 0002 2096 6237] Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Deb Aja, Western District Supervisor – Solid Waste Section Chris Hollinger, Compliance Officer – Solid Waste Section Robert Wall, Division Vice President – Waste Connections, Inc. Tyler Fitzgerald, District Manager – Waste Connections, Inc.