4204_INSP_20160602

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 4

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Halifax
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 4204-INDUS-1994
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill X DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: June 2, 2016 Date of Last Inspection: January 15, 2016

FACILITY NAME AND ADDRESS:
Halifax Coal Ash Landfill
921 Liles Road
Halifax, NC 27839

GPS COORDINATES: N: 36.38029 W: -77.81138

FACILITY CONTACT NAME AND PHONE NUMBER:
Ed Stanfield, Tel- 252-586-7516, [e-mail]
Greg Griffin, Tel- 252-583-1451, [e-mail]

FACILITY CONTACT ADDRESS:
Halifax County Industrial Coal Ash Landfill
PO Box 70
Halifax, NC 27839

PARTICIPANTS:
Ed Stanfield, Halifax County, Landfill Supervisor
Greg Griffin, Halifax County, Director of Public Utilities
Shawn McKee – NCDEQ, Solid Waste Section
Mary Whaley – NCDEQ, Solid Waste Section

STATUS OF PERMIT:
Active. Permit 4204-INDUS-1994 was issued on March 27, 2012 and will expire on March 27, 2017

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
15A NCAC 13B .0505 (3)(b) Areas which will not have additional wastes placed on them for 12 months or more, but
where final termination of disposal operations has not occurred, shall be covered with a minimum of one foot of
intermediate cover

During the August 10, 2015 inspection, significant erosion was observed on side slopes such that coal ash had washed
into perimeter ditches and had washed into the sediment basin. On October 20, 2015 the Division of Waste
Management, Solid Waste Section (Section) received Halifax County Ash Monofill (NC Permit 42-04-INDUS-1994),
Conceptual Filling and Intermediate Cover Plan, prepared for Halifax County, prepared by Smith-Gardner. On
October 22, 2015, the Solid Waste Section concurred with the plan. The northern slope of the landfill has had soil cover
placed, and been graded and seeded per the Cover Plan. The western slope has been prepared for placement of
intermediate cover (identified as Sequence No. 3B in the Cover Plan). Other slopes have been regraded to reduce
erosion. Continue to place intermediate cover on all slopes in accordance with the Cover Plan. Unresolved.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 2

15A NCAC 13B .0203(d) states “By receiving solid waste at a permitted facility, the permittee(s) shall be considered to
have accepted the conditions of the permit and shall comply with the conditions of the permit.”

Ops Plan 2.5.6.2 states “unless suitable vegetation can be established on the surface of the ash a 12-inch layer of soil
cover should be placed over the ash on all outer side slopes. This intermediate cover should be seeded immediately and
graded such that all precipitation run-off is channeled to the surface water systems.”

The facility is in violation of the above rule in that it failed to prevent the erosion of the side slopes by not providing soil
cover and/or permanent vegetation as noted in Ops Plan 2.5.6.2.

The northern slope of the landfill has had soil cover placed, and been graded and seeded per the Cover Plan. The
western slope has been prepared for placement of intermediate cover (identified as Sequence No. 3B in the Cover Plan).
Other slopes have been regraded to reduce erosion. Continue to place intermediate cover on all slopes in
accordance with the Cover Plan. Unresolved.

OBSERVED VIOLATIONS:
None.

ADDITIONAL COMMENTS
The coal ash landfill is one of several units located at the facility owned by Halifax County. The other units include a
construction and demolition landfill, a municipal solid waste (MSW) transfer station, and a closed unlined MSW landfill.

1. The Permit to Operate shall expire March 27, 2017. Pursuant to 15A NCAC 13B .0201(g), no later than
November 27, 2016, the permittee must submit a request to the Section for permit review and must update
pertinent facility plans including, but not limited to, the facility operation and waste screening plans.

2. The coal ash landfill is permitted to receive only coal combustion by-products in accordance with the approved
plan. Municipal solid waste, construction and demolition debris waste, land clearing and inert debris, hazardous
waste, special waste, and liquid waste are prohibited from disposal in the coal ash landfill.

3. The facility operator must complete an approved operator training course in compliance with G.S. 130A-309.25.
The following facility staff are Certified Landfill Operations Specialists:

Edgar Stanfield, LF-2001362, expires June 13, 2016
Randy Pike, LF-2015025, expires May 20, 2018

4. The landfill is permitted to receive waste only from the coal-fired power plant in Weldon, NC (which is
currently owned by the Westmoreland Coal Company). The Westmoreland plant in Weldon is not currently
running at full capacity, such that ash disposal needs are less, and vary by seasonal demand for electricity. The
amount of coal ash being brought to the industrial landfill has fallen off significantly since the landfill was first
permitted due to the cutback in operating time at the plant. Since July 1, 2015, a total of 4,846.19 tons of coal
ash and 3,518.23 tons of ash “sludge” has been disposed of at 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 3 of 3

5. Groundwater, surface water, basin effluent, and stream sediment locations are sampled semi-annually. The last
sampling events occurred on August 24, 2015 and February 25, 2016. Results from these events were reviewed
during the inspection. Sampling results were consistent with previous events; no concerns were noted.

6. Repairs to monitoring points with previously noted concerns were discussed and noted during the inspection.
Correction have been made as noted below:

4204-INDUS-1994
Monitoring Well
ID Well Tag Concrete Pad Comments
Groundwater Monitoring Wells
MW-8 Yes Yes Well tag has been stamped with an “8”
MW-17 No No Concrete pad has been repaired
Surface Water Locations
SW-3 NA NA Sign has been posted at sample location
Basin 1 NA NA Sign has been posted at sample location
Sediment Basin Sample Locations
SS-1 NA NA Sign has been posted at sample location
SS-2 NA NA Sign has been posted at sample location

7. No unpermitted waste was observed in the landfill during the inspection.

8. Ash is currently being placed in Cells 1 and 2. Spreading and compaction of the ash is performed with a D6
bulldozer.

9. Edge-of-waste markers were in place and being maintained.

10. Dust control is performed consistent with the facility’s Fugitive Dust Control Plan. During periods without
significant precipitation, facility staff should be extra diligent in monitoring and addressing dusting on and around
the working face.

11. Heavy rains occurred the night before the inspection. Erosion was observed on side slopes such that coal ash
had washed into perimeter ditches. During the August 10, 2015 inspection, significant erosion was observed on
side slopes such that coal ash had washed into perimeter ditches and had washed into the sediment basin. On
October 20, 2015 the Division of Waste Management, Solid Waste Section (Section) received Halifax County
Ash Monofill (NC Permit 42-04-INDUS-1994), Conceptual Filling and Intermediate Cover Plan, prepared for
Halifax County, prepared by Smith-Gardner. On October 22, 2015, the Solid Waste Section concurred with the
plan. The northern slope of the landfill has had soil cover placed, and been graded and seeded per the plan.
The western slope has been prepared for placement of intermediate cover (identified as Sequence No. 3B in the
Cover Plan). Intermediate cover is scheduled to be placed by the end of July 2016. Other slopes have been
regraded to reduce erosion. Continue to place intermediate cover on all slopes in accordance with the
Cover Plan.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 4

Toe of the western slope; being prepared for cover Erosion on southern slope after heavy rains

12. As a reminder, per Permit to Operate, Condition # 59 “Ash which has been placed to final elevations around the
perimeter of the facility must be covered with a minimum of 12 inches of soil. Final cover and seeding must be
implemented within 30 days of an area reaching final grade.” Additionally, per 15A NCAC 13B .0505(3)(c)
“After final termination of disposal operations at the site or a major part thereof, or upon revocation of a permit,
the area shall be covered with at least two feet of suitable compacted earth.”

13. The sediment basin appeared to be functioning as designed at the time of the inspection. Continue to monitor
the inlet to the basin for any signs of ash migration.

Please contact me if you have any questions or concerns regarding this inspection report.

_ Phone: [phone]
Shawn McKee
Environmental Senior Specialist
Regional Representative

Sent on:
June 9, 2016
Email:
X
Hand delivery US Mail Certified No. [ _]

Copies: Ellen Lorscheider, Section Chief, Solid Waste Section
Ed Mussler, Permitting Branch Head, Solid Waste Section
Jason Watkins, Field Operations Branch Head, Solid Waste Section
Elizabeth Werner, Permitting Hydrogeologist, Solid Waste Section
Larry Frost, Engineering Project Manager, Solid Waste Section
Jessica Montie, Compliance Officer, Solid Waste Section