1304_INSP_20230725

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: CABARRUS
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 1304-MSWLF-1992
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 7/25/23 Date of Last Inspection: 6/29/23
FACILITY NAME AND ADDRESS: BFI-Charlotte Motor Speedway Landfill V 5105 Morehead Road Concord, North Carolina 28027 GPS COORDINATES (decimal degrees): Lat.: 35.35196 Long.: -80.66805 FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Andrew Magee, General Manager – Republic Services, Inc. Telephone: [phone]
Email address: [e-mail] FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS:
Andrew Magee, General Manager – Republic Services, Inc. Mike Gurley, Environmental Manager – Republic Services, Inc Jason Watkins, DEQ – Solid Waste Section
Deb Aja, DEQ – Solid Waste Section Teresa Bradford, DEQ – Solid Waste Section
STATUS OF PERMIT:
A Permit Amendment to the Permit to Construct Phase 4 and the Permit to Operate Phases 1-3 was issued to BFI Waste Systems of North America, LLC, a wholly owned subsidiary of Republic Services, Inc. on July 20, 2022. In accordance with N.C.G.S. 130A-294(a2), the Permit is for the life-of-site of the facility which is defined as the period from the
initial receipt of solid waste at the facility until the facility reaches its final permitted elevations, which period shall not exceed 60 years. Permit number 1304-MSWLF-1992 was approved to begin waste receipt operations on March 6, 1992, therefore the Permit shall expire on March 6, 2052. On October 3, 2022, the facility received approval from the Solid
Waste Section to operate Phase 3, Cell 2M. PURPOSE OF SITE VISIT:
Follow-up Inspection STATUS OF PAST NOTED VIOLATIONS:
A. 15A North Carolina Administrative Code 13B .1626(2)(b) for failing to adequately cover all disposed waste with six inches of earthen material. Corrective Actions in Progress
B. 15A North Carolina Administrative Code 13B .0203(d) for failing to adequately cover all disposed waste with six inches of earthen material. Corrective Actions in Progress C. 15A North Carolina Administrative Code 13B .1626(11) for failing to collect and return windblown waste to the working face at the end of each operational day. Corrective Actions in Progress
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 9
D. 15A North Carolina Administrative Code 13B .0203(d) for failing to collect and return windblown waste to the working face at the end of each operational day. Corrective Actions in Progress
7/25/23: View of uncovered or partially covered waste on the eastern side of the
landfill. (Photo by T. Bradford)
7/25/23: View of uncovered or partially covered waste on the eastern side of the landfill. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 9
7/25/23: View of uncovered or partially covered waste on the southern side of Cell 2M. (Photo by D. Aja)
7/25/23: View of uncovered or partially covered waste on the southern side of
Cell 2M. (Photo by D. Aja).

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 9
7/25/23: View of uncovered or partially covered waste on the top of the landfill. (Photo by T. Bradford)

7/25/23: View of uncovered or partially covered waste on the top of the landfill.
(Photo by T. Bradford)

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 9
7/25/23: View of uncovered or partially covered waste on the top of the landfill and along the access road. (Photo by T. Bradford)
E. 15A North Carolina Administrative Code 13B .1626(1)(g) for allowing waste to be displaced and leave the base liner system during recent rain events due to failure to maintain soil cover. Corrective Actions in Progress

7/25/23: View of waste that has been washed over the berm from recent rains. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 9
F. 15A North Carolina Administrative Code 13B .1626(8)(d) for failing to contain leachate within the lined disposal cell or leachate collection and storage system. Corrective Actions in Progress
7/25/23: View of leachate collected into the perimeter ditch outside of the lined disposal cell on the eastern side of Cell 2J. (Photo by T. Bradford)

OBSERVED VIOLATIONS:
No new violations.

ADDITIONAL COMMENTS
1. The facility is permitted to receive solid waste generated from within the City of Concord, Cabarrus County, the State of North Carolina, and the following counties in the State of South Carolina: Cherokee, York, Lancaster, Chesterfield and Chester.
2. Proper signage was observed at the entrance of the facility. 3. A gate is provided at the entrance of the facility to prevent unauthorized access.
Operations Inspection of the MSWLF: 4. This follow-up inspection was conducted to determine if compliance actions were completed for the violations noted in the previous inspections on December 7, 2022, January 27, 2023, April 19, 2023 and June 29, 2023. 5. Since the July 7, 2023 Notice of Additional Violations letter was sent to the facility, several updates have been submitted by e-mail from Mr. Magee to Section Staff indicating that efforts have begun to cover Phase 3 - Cells 2J, 2K and 2M and the top of the landfill. Mr. Magee stated that a third-party contractor was hired to assist in covering the landfill.
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 7 of 9
6. During this inspection, additional soil cover was observed to have been added to the upper portion of the eastern and southern landfill side slopes from Cell 2I through 2M. Cover had also been added to the lower portion, but waste was still exposed throughout the lower side slopes of the landfill. Also, additional soil cover was observed to have been added on the upper deck of the landfill near the tippers. However, a large area of the upper deck of the landfill and along the access road leading to the upper deck had waste exposed. It was evident that landfill equipment had been
traveling over this area without restrictions and damaging any prior cover. Also, the exposed waste on the western side of Cell 2F left uncovered from the construction of Phase 4 had not been covered. Please see the Past Noted Violations Section of this report.
7/25/23: View of additional soil cover added to the upper portion of the eastern side slope and of uncovered or partially covered waste on the bottom portion. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 9
7/25/23: View additional soil cover added on the upper deck of the landfill near the tippers. (Photo by T. Bradford)
7. Due to space limitations in the active disposal area of Cell 2M, the facility continues to operate the tippers at the top of the landfill and push waste multiple hundred feet down the side slope to the working face. As noted in previous
inspection reports, this is an inefficient method of managing the waste that should be avoided during most times of the operation of a landfill, in that it requires extra equipment and manpower to handle the waste multiple times. Further, it disturbs previously covered portions of the landfill and creates a much larger active area each day than the facility can adequately cover. 8. Since the previous inspection, the Department continues to receive odor complaints from neighboring communities. The extensive areas of the landfill that remain un- or partially covered can be the primary source of on-going odor generation from this facility impacting neighboring communities. 9. During the inspection, sporadic light odors were detected in two locations of the landfill while observing areas of cover placement. No additional odor investigation occurred. 10. Leachate continues to be collected in the perimeter ditch outside of the lined disposal cell on the eastern side of Cell 2J. As required in the NOAV, the facility was to immediately make repairs to the leachate outbreaks on the eastern side slope of Cell 2J, pump the leachate from the ditch and return the leachate to the leachate collection system. Any soil that was impacted by the leachate release was to be excavated at least 12 inches in depth and the soil disposed of in the active landfill. Confirmation sampling of the remaining soil was required to determine if all impacted soil had been
removed. Copies of the sampling results were required to be sent to Jackie Drummond for review. The facility stated that the leachate had been pumped out of the ditch on the day of the previous inspection. The facility also stated that the sediment basin had been sampled and analytical results had not been received. While some repair to the side slopes including the placement of soil had commenced above the area of the releases, there remains additional grading that is needed in this area to address washouts and the areas where the outbreaks occurred to fully stabilize the area and to prevent additional runoff into the ditch area. Please see the Past Noted Violations Section of this report. 11. Edge of waste markers were being maintained. 12. Initial subgrade soil placement was occurring in future Phase 4. 13. Access roads were well maintained. 14. Access roads around the landfill unit were well maintained.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 9
15. Within 10 days of receipt of this inspection report, please submit to Teresa Bradford a detailed list of actions that the facility has taken to date to come into compliance with the July 7, 2023 NOAV. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] Teresa N. Bradford Environmental Senior Specialist
Regional Representative
Sent on: 8/1/2023 X Email Hand delivery US Mail X Certified No. []
Copies: Ed Mussler, Section Chief – Solid Waste Section
Sherri Stanley, Permitting Head – Solid Waste Section Victor Unnone, Assistant Attorney General Jason Watkins, Field Operations - Solid Waste Section
Deb Aja, Western District Supervisor - Solid Waste Section Chris Hollinger, Compliance Officer - Solid Waste Section Mike Gurley, Facility Environmental Manager - Republic Services
Mark Stanley, Mid-Atlantic Area Environmental Manager – Republic Services