1304_INSP_20231006

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: 9/7/23 & 10/6/23 Date of Last Inspection: 7/25/23
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. (9/7/23 & 10/6/23) Mark Stanly, Mid-Atlantic Area Environmental Manager – Republic Services, Inc. (9/7/23 & 10/6/23) Mike Gurley, Environmental Manager – Republic Services, Inc. (10/6/23)
Teresa Bradford, DEQ – Solid Waste Section (9/7/23 & 10/6/23) Charles Gerstell, DEQ – Solid Waste Section (9/7/23) Deb Aja, DEQ – Solid Waste Section (10/6/23)
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: Information and photographs contained directly below is representative of inspections on 9/7/23 & 10/6/23 and show progress being made towards compliance with past noted violations. Note that 2 violations have now been fully resolved.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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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

9/7/23: 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 3 of 15
10/6/23: View in foreground shows partially covered waste on the upper deck after blading. The area shown in the background is the area in the previous photograph taken on 9/7/23.
Additional soil has been added to this area. (Photo by T. Bradford)
9/7/23: View of uncovered or partially covered waste on Cell 2M/2K. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 15
10/6/23: View of soil cover on side slope of Cell 2M. (Photo by T. Bradford)
9/7/23: View of uncovered or partially covered waste on Cell 2M. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 15
9/7/23: View of uncovered or partially covered waste on Cell 2M. (Photo by T. Bradford)
10/6/23: View of covered waste on Cell 2M. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 15
10/6/23: View of stockpile soil and covered waste on Cell 2M. (Photo by T. Bradford)
10/6/23: View of uncovered waste under and surrounding the wind fence. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 15
9/7/23: View of uncovered or partially covered waste on Cell 2M. (Photo by T. Bradford)
10/6/23: View of soil cover on the southern side slope of Cell 2M. (Photo by T. Bradford)
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. Windblow litter had been removed from the sediment basin and facility grounds. Therefore, this violation is considered resolved.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 15
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. Windblow litter had been removed from the sediment basin and facility grounds. Therefore, this violation is considered resolved. 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
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. The leachate in the perimeter ditch on the eastern side slope of Cell 2J that was observed during the 6/29/23 and 7/25/23 inspection had been removed and the ditch repaired. Corrective Actions in Progress
9/7/23: View of perimeter ditch on the eastern side of Cell 2J. (Photo by T. Bradford)
OBSERVED VIOLATIONS: A. 15A North Carolina Administrative Code 13B .1626(8)(d) states: Leachate shall be contained within a lined disposal cell or leachate collection and storage system. All leachate shall be treated, as required by the receiving facility, prior to discharge. 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.
On September 7, 2023, multiple leachate outbreaks were observed on the eastern side slope of Cell 2J and Cell 2K. A leachate outbreak in Cell 2K resulted in leachate being discharged outside of the lined disposal cell. During the inspection on October 6, 2023, repairs had been made to the side slope of Cell 2J and 2K, however, the area outside of
the liner that was impacted by the leachate outbreak observed on September 7, 2023 had not been removed (see photo below).
On October 6, 2023, no leachate outbreaks were observed on the eastern side slope of Cell 2J, however, another leachate outbreak in Cell 2K resulted in leachate being discharged outside of the line disposal cell. On October 6, 2023, facility staff sent an e-mail to Section staff with a photograph confirming that the outbreak was repaired.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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9/7/23: View of leachate flowing past the lined disposal cell. (Photo by T. Bradford)
10/6/23: View of area of leachate release observed on 9/7/23. Impacted soil has not been
removed. (Photo by T. Bradford)

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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10/6/23: View of leachate flowing past the lined disposal cell. (Photo by T. Bradford)

Photograph sent by Andrew Magee on 10/6/23 after the inspection.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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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, June 29, 2023 and July 25, 2023. 5. Since the July 7, 2023 Notice of Additional Violations letter was sent to the facility, Mr. Magee has submitted regular updates to Section Staff indicating efforts undertaken to cover Phase 3 - Cells 2J, 2K and 2M and the top of the landfill
and repair leachate outbreaks. 6. During the October 6, 2023 inspection, a significant amount of soil cover had been added to the eastern and southern landfill side slopes from Cell 2I through 2M and on the upper deck. The upper deck had been bladed so that the ruts
were removed throughout most of the area. Adequate soil cover was observed on a portion of the upper deck. The remaining area closest to the working face on the upper deck and in the area surrounding the windblown fence on Cell 2M needs additional cover as discussed during the inspection. Landfill slopes had been graded in preparation for
seeding. Waste was observed on the surface and in the soil throughout areas where additional soil had been placed. Facility staff stated that they were in the process of hand removing waste visible at the surface. Prior to seeding ensure that all waste is covered with at least six inches of soil cover. Please see the Past Noted Violations Section of this report.
10/6/23: View of additional soil cover added to the eastern side slope. (Photo by T. Bradford)
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

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10/6/23: View of exposed waste on surface in an area that additional soil cover was added to on the eastern side slope. (Photo by T. Bradford) 7. Soil cover has been placed on the exposed waste at the tie-in between Phase 4 and the western side of Cell 2F that was
observed during the June 29, 2023 inspection. 8. The facility has made repairs to the side slopes of Cell 2J and 2K including the placement of soil and grading. The leachate outbreaks observed during the September 7, 2023 inspection had been repaired. On October 6, 2023, no leachate outbreaks were observed on the eastern side slope of Cell 2J, however, another leachate outbreak in Cell 2K resulted in leachate being discharged outside of the line disposal cell. Please see the Observed Violations Section of this report. Facility staff stated that a new standard operating procedure has been established that requires the landfill
operations teams to canvas the landfill prior to closing for any seeps and to repair them immediately. At the conclusion of each day, written confirmation is received if there are any seeps on-site; if there are seeps, visual confirmation of the repairs is required. 9. Facility staff stated that the leachate sump for Cell 2J and 2K is being pumped weekly to help control leachate outbreaks.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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10/6/23: View of repaired side slope of Cell 2K. (Photo by T. Bradford)
10/6/23: View of repaired side slope of Cell 2J/2K. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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10/6/23: View of repaired side slope of Cell 2J. (Photo by T. Bradford) 10. Windblown litter was not observed during the inspection. Facility staff stated that crews are onsite daily to remove windblown litter. The sediment basin had been cleaned out to remove windblown litter. 11. Seeding was underway on the slope of Cell 2M. Facility staff stated that the seeding would be completed in approximately six weeks pending weather conditions. 12. The odor neutralizing system along the southwest corner of Cell 2M was observed operational during the inspections.
9/7/23: View of odor neutralizing system on the Cell 2M. (Photo by T. Bradford)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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13. Edge of waste markers were being maintained. 14. Access roads were well maintained. 15. As noted above, substantial progress has been made in recent weeks to remedy the previously noted violations though some issues remain unresolved. All applicable conditions for compliance and deadlines noted in the September 20, 2023 Order remain in effect. Please continue to work on any outstanding matters and keep the Section updated as progress is made.
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: 10/17/2023 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 Jackie Drummond, Hydrogeologist – 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 Mike Neafsey, Area Post Collections Manager - Republic Services