4104_INSP_20240327

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 4
UNIT TYPE:
MSWLF X COUNTY: Guilford
X PERMIT NO.: 41-04
FILE TYPE: COMPLIANCE

Date of Site Inspection: March 27, 2024 Date of Last Inspection: September 18, 2023
FACILITY NAME AND ADDRESS:
City of High Point Kersey Valley MSW Landfill 3940 E. Kivett Drive
High Point, NC 27261 GPS COORDINATES: Lat.: 35.95416 Long.: -79.93094 FACILITY CONTACT NAME AND PHONE NUMBER:
Mike Spencer, Solid Waste Disposal Superintendent – City of High Point w. 336-883-3433 c. 336-688-3454
[e-mail] FACILITY CONTACT ADDRESS:
City of High Point Mike Spencer, Solid Waste Disposal Superintendent P.O. Box 230
High Point, NC 27261
PARTICIPANTS:
Chuck Kirchner, Environmental Senior Specialist – Solid Waste Section (SWS) Mike Spencer, Solid Waste Disposal Superintendent – City of High Point Brad Embry, Assistant Solid Waste Disposal Superintendent – City of High Point STATUS OF PERMIT:
Permit to Operate (PTO) issued February 5, 2024 Phase 1-6 - Life of Site Permit Permit to Construct (PTC) issued same date for Phases 7-10 and Vertical Expansion over Areas 1, 2 & 3 PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None
OBSERVED VIOLATIONS: A. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.” 1. Permit to Operate No. 41-04, ATTACHMENT 3, PART I, General Facility Operation Conditions #8 states, “The permittee must develop, and use, a training and screening program at the facility for detecting and preventing unauthorized wastes from being accepted at the facility. At a minimum, the program must include: a. Random inspections of incoming loads or other comparable procedures.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 4
b. Records of all inspections.
c. Training of personnel to recognize hazardous, liquid and other excluded waste types. d. Development of a contingency plan to properly manage any identified hazardous, liquid, or other excluded or unauthorized wastes. The plan must address identification, removal, storage and
final disposition of these wastes.”
B. 15A NCAC 13B .1626(1)(f) states: “Owners or operators of MSWLF units shall develop and implement a waste screening plan as required by G.S. 130A-295.6(g) in accordance with the effective date and applicability requirements of S.L. 2007-550, s. 9.(b). The plan shall comply with 40 CFR 258.20 and shall include screening for the wastes
prohibited by Sub-Item (1)(b) of this Rule. Owners and operators of MSWLF units that are not subject to G.S. 130A-295.6(g) shall develop and implement a waste screening plan that shall comply with 40 CFR 258.20 and shall include screening and a contingency plan for the wastes prohibited by Sub-Item (1)(b) of this Rule.” The City of High Point is in violation of 15A NCAC 13B .0203(d) and 15A NCAC 13B .1626(1)(f) in that random inspections of incoming loads were not being conducted and the approved waste screening plan was not being implemented. The last recorded inspection of incoming loads was on March 17, 2024, however, only one other inspection was conducted in 2024. Facility staff confirmed that random inspections of incoming loads were not being done at this landfill. To come into compliance the facility shall conduct waste screenings as described in section 2.3 of the February
2022 Operations Manual.

ADDITIONAL COMMENTS
On March 27, 2024, Chuck Kirchner met with Mike Spencer and Brad Embry to conduct a comprehensive inspection of the Kersey Valley MSW Landfill located off E. Kivett Road in High Point, Guilford County. Facility Information 1. The municipal solid waste (MSW) landfill is located on property owned by the City of High Point. The property also contains a treatment and processing (T&P) operation, a convenience center, and a temporary debris storage and reduction site (TDSR). 2. The landfill is in operation Monday through Friday 7:30 am to 4:30 pm. The convenience center near the entrance is open on Saturday from 7:00 am to 1:00 pm.
3. The MSW landfill consists of two lined fill areas: Area 1, Phases 1 – 3A and Area 2, Phases 4 and 5A and 5B.
4. The MSW landfill has completed construction of Phase 6 and has submitted the CQA report. 5. The MSW landfill Area 1 is inactive. It is capped. A partial closure letter, dated December 19, 2016, was issued by the SWS for approximately 23.8 acres (of the approximately 39.1-acre area). 6. The facility is rerouting a portion of Kersey Valley Road that runs between landfill Areas 1 and 2 and will adjoin the landfill areas. The landfill area between the two phases will be Phase 5C. 7. The facility address for landfill Area 1 is 3854 E. Kivett Drive, High Point. 8. The facility address for landfill Area 2 is 3940 E. Kivett Drive, High Point. 9. The facility does not accept scrap tires. 10. White goods are placed in a roll-off container at the convenience center. The white goods are managed
by the City of High Point Material Recovery Facility (MRF) and are hauled off once a week. 11. The facility has installed a landfill gas extraction network in Area 1 for expected future use. Landfill gas extraction wellheads have not been installed and a landfill gas collection station has not been constructed.

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
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 4

12. The facility has installed four candlestick flares atop Area 1. The flares are used for the combustion of passive landfill gas. The flares automatically ignite when needed. If the flares malfunction, landfill gas will vent via the unfinished landfill gas extraction wellhead caps. The wellhead caps are designed to pop
off to vent landfill gas.
Records Review
13. The facility site plan, permit, and operations plan were discussed. 14. The following are certified personnel:
a. Michael Spencer, Manager of Landfill Operations, No. 905194, exp. 09/07/25 b. Terry Kinney, Certified Landfill Operations Specialist, No. 2019025, exp. 4/16/25 c. Brian Craft, NC Certified Landfill Operator, Cert. No. 18-020-00398, Exp. 11/1/27 d. Andrew Dennis, NC Certified Landfill Operator, Cert. No. 21-020-00614, Exp. 8/18/27 e. Michael Lester, NC Certified Landfill Operator, Cert. No. 18-020-00400, Exp. 11/1/27 f. Samuel Barefoot, NC Certified Landfill Operator, Cert. No. 21-020-00632, Exp. 11/3/27 g. Ethan Mode, NC Certified Landfill Operator, Cert. No. 18-020-00398, Exp. 11/1/27
15. The facility is permitted to receive solid waste from Davidson, Forsyth, Guilford, and Randolph Counties. 16. The facility maintains records of the amount of solid waste received. The amount of solid waste received from January 1, 2024 through March 27, 2024 is 44,037.59 tons. 17. The facility annual report (FAR) was received by the SWS dated July 21, 2023. Facility throughput for July 2022 through June 2023 is 125,777 tons of which 36 tons were recovered. 18. Waste Screening shall be conducted as described in the February 2022 Operations Manual, Section 2.3.1, located on pages 14-15 of the manual. At least one vehicle per week, but not less than 1% by weight of the waste stream entering the facility (based on the previous week’s total), will be randomly selected by inspection personnel. See Observed Violation above. 19. The facility maintains semiannual groundwater and surface water monitoring and leachate test records
submitted by Babb & Associates, P.A., analyzed by Environmental Conservation Laboratories, Inc. (ENCO). Records for groundwater, surface water monitoring and leachate testing conducted on April 4-
5, 2023 and November 7-9, 2023 were observed. An exceedance is noted for each event. 20. The facility maintains quarterly methane monitoring records. Monitoring is conducted by Smith+Gardner, Inc. Records for methane monitoring conducted February 14, 2023 (1st quarter), May 14,
2023 (2nd quarter), September 28, 2023 (3rd quarter), December 6, 2023 (4th quarter) and February 29, 2024 (1st quarter) were observed. Monitoring results do not indicate an exceedance of the methane or hydrogen sulfide lower explosive limit (LEL).
21. The GEM5000, S/N G506472, was last calibrated in January 2023. 22. The facility has a stormwater National Pollutant Discharge Elimination System (NPDES) permit, General Permit No. NCG120000. The NPDES permit was issued November 1, 2018 and will expire on June 30,
2026. 23. The facility maintains a 2021 Title V Annual Compliance Certification Air Permit, Permit Number 10517T01, Facility ID 4101253. Compliance certifications are performed annually.
24. The facility has three open erosion and sedimentation control plans with NCDEMLR. GUILF-2000-008 certificate of approval for CHP Kersey Valley MSW Landfill Phase 3 and GUILF-2010-050 certificate of approval for CHP Kersey Valley Landfill – Phase I. Permit number GUILF-2023-005 has recently been
added for Phase 6 construction which is scheduled to start soon.
25. The leachate collection lines are required to be flushed and camera inspected once every five years. The leachate collection lines were flushed and camera inspected by Jetclean America in February 2022.
Site Inspection 26. The facility is currently operating in Area 2, along the top of Phase 5A. 27. The facility is permitted to use tarps. Three tarps are commonly used to cover the working face Monday through Thursday and soil cover is used on Friday according to Mr. Spencer.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 4
28. Some exposed waste near the working face observed. This may be from the day’s activities. Any exposed waste shall be covered at the end of each working day with a minimum six inches of earthen material or approved alternative daily cover as required in 15A NCAC 13B .1626(2) to control disease vectors, fires, odors, blowing litter, and scavenging. 29. The working face was small and compact. 30. No unauthorized waste was observed in the working face.
31. The facility has a leachate pump station that is connected to a pump station located on the south side of the landfill, east of Kersey Valley Road. The municipal sewer system collects leachate from Areas 1 and 2. 32. The facility has a 340,000-gallon leachate storage tank with secondary containment that is no longer
used. 33. Phase I has a temporary cap. No eroded rills and a good grass cover were noted in this area. Continue to maintain this area as needed. 34. The facility has white edge of waste markers along Areas 1 and 2. 35. During the inspection, no odor off site was detected. 36. Many inactive areas around the landfill were observed to have a good grass cover. Continue to seed and mulch any bare areas or areas with sparse grass cover until vigorous permanent grass cover germinates in all disturbed areas. 37. A convenience center is located near the scale house for residents to drop off waste. Heavy traffic observed this inspection. Traffic appeared to be managed in an orderly manner and minimal waste was observed outside of the containers in this area. 38. No windblown litter observed during this inspection. General Comments
39. The facility has a wood waste treatment and processing (T&P) operation. Land clearing debris, high carbon to nitrogen ratio material, pallets, treated wood, lumber scraps, engineered wood, and furniture
manufacturing waste is ground for use only on the landfill working face access road in lined areas during inclement weather. 40. When the woody material is ground, it is directly off-loaded into roll-off containers or dump trucks and
brought to the landfill operations area. Ground treated and engineered wood shall not be stored on the ground outside of the lined landfill and leachate control areas. 41. Good fire access buffers were observed around the T&P stockpile material this inspection. 42. The area allotted for the wood waste T&P operation is ~ 2 acres. The area is also designated as a temporary debris storage and reduction site (TDSR), number DS41-004. 43. The City of High Point Fire Department can be contacted to respond to an emergency at the landfill. 44. Access roads are of all-weather construction. 45. The facility has proper signage. 46. The facility entrance is secured by a locked gate. Please contact me if you have any questions or concerns regarding this inspection report. ________________________________________ Phone: [phone] _ Chuck Kirchner Environmental Senior Specialist
Regional Representative
Sent on: April 2, 2024 X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor - Solid Waste Section Melinda King, Assistant Public Services Director – City of High Point, [e-mail]