1910_Brickhaven_INSP_20161011

FACILITY COMPLIANCE INSPECTION REPORT
Department of Environmental Quality
Division of Waste Management - Solid Waste Section

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Chatham
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 1910-STRUC-2015
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: October 11, 2016 Date of Last Inspection: April 18, 2016

FACILITY NAME AND ADDRESS:
Brickhaven No. 2
1473 Moncure-Flatwood Road
Moncure, NC

GPS COORDINATES: N: 35.596 W: -79.010

FACILITY CONTACT NAME AND PHONE NUMBER:
Glenn Amey, PG, Engineering Manager, Direct: 704-731-2202, [e-mail]

FACILITY CONTACT ADDRESS:
Green Meadow, LLC
352 Brickyard Road
Sanford, NC 27330
[phone]

PARTICIPANTS:
Shawn McKee, NCDEQ, Solid Waste Section
Elizabeth Werner, NCDEQ, Solid Waste Section
Shannon Aufman, NCDEQ, Solid Waste Section
Jacob Buda, Charah, Inc.
Kyle Hoover, Charah, Inc.

STATUS OF PERMIT:
Permit to Construct and Operate issued June 5, 2015
This permit shall expire June 5, 2025

PURPOSE OF SITE VISIT:
Comprehensive inspection.

STATUS OF PAST NOTED VIOLATIONS:
None.

OBSERVED VIOLATIONS
None.

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 2 of 5

ADDITIONAL COMMENTS
The site is a lined coal combustion products structural fill permitted for mine reclamation in conjunction
with NCDEQ DEMLR Mine Permit 19-25.

1. The structural fill permit, site plan, and operations plan were discussed during the inspection. The
Permit to Construct and Operate was issued on June 5, 2015 and approves the operation of Cells 1
through Cell 5. The permit is subject to review by June 5, 2020.

2. Approval to commence structural fill operations in Subcell 2C and 2D was issued by the Solid Waste
Section on September 20, 2016.

3. According to the approved site operations plan, operations can occur 24 hours a day, 7 days per
week. Solid Waste Section approval is needed if there is a change in operating hours.

4. A sign providing the facility name, permit number, operating hours, and emergency contact
numbers is posted at the site entrance.

5. A responsible individual trained in operations must be on-site at all times during all operating
hours.

6. Training records were reviewed during the inspection. Spill Prevention Control and
Countermeasure (SPCC) Plan training and Waste Management training are required for all staff
both initially as new staff start and annually thereafter. The most recent training was conducted on
May 5, 2016.

7. Financial assurance must be continuously maintained for the duration of the site operations and post
closure care in accordance with §130A-309.221. The owner and operator must annually adjust cost
estimates for inflation. Financial assurance documentation for the structural fill was reviewed during
the inspection. The approved financial assurance includes $5,992,590 for closure, $2,208,000 for
post-closure care, $2,000,000 for potential assessment and corrective action, and $65,000 for
Departmental Costs to Respond to an Incident.

8. The structural fill began placing coal combustion products on October 23, 2015. At the time of the
inspection, trains were not being received at the structural fill because of disruptions caused by
Hurricane Matthew. During normal operations, approximately one train per day of coal combustion
products (CCPs) arrive per day; approximately half coming each from the Duke Energy facilities of
Sutton Steam Plant and Riverbend Steam Station (approximately 13 per month from Sutton and
approximately 14 per month from Riverbend).

9. As of the date of the inspection, 1,966,960.89 tons of CCPs have been placed within the structural
fill. Of that total tonnage, 1,940,560.80 tons were received by rail and 26,300.09 tons were
received by truck. Since March 9, 2016, all ash arriving at the site has been by rail. Each train has
up to 85 cars; each train has the capacity to carry up to 8,500 tons of CCPs. Ash is conditioned to
18-20% moisture content prior to transport.

10. Annually by August 1, the Permittee must submit an annual facility report to the Section. During
the time period between July 1, 2015 and June 30, 2016, the facility reported that 1,105,401.45
tons of ash were placed in the structural fill. Scales are being used routinely to weigh the amount
of coal combustion products received.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 5

11. The structural fill has an approved dust control plan. Water trucks are utilized to control road dust,
as needed. Water trucks were operating at the time of the inspection. Dust control checks occur
daily at 9am and 2pm and are recorded. Records from 1/1/16 to 3/31/16 were reviewed during the
inspection.

12. Independent background samples from each of the compliance groundwater monitoring wells and
surface water sampling locations have been obtained and analyzed for constituents listed in
Appendix III and IV in accordance with 40 CFR 257.94(b). Additionally, during the first year of
operation eight (8) independent samples from each of the compliance groundwater monitoring wells
and surface water sampling locations were sampled and analyzed for the Appendix III and IV
constituents. Results have been submitted to the Solid Waste Section.

13. Compliance groundwater monitoring wells, surface water locations and leachate monitoring ports are
sampled semi-annually and analyzed for constituents listed in the approved Water Quality
Monitoring Plan. Results are submitted to the Solid Waste Section.

14. A readily accessible unobstructed path shall be cleared and maintained so that four-wheel drive
vehicles may access monitoring locations, at all times. Groundwater monitoring wells are well
marked and protected from vehicular traffic by yellow bollards and flags. All groundwater
monitoring wells must be secured with locks and have permanent well tags.

15. The following monitoring wells were observed during this inspection:

1910-STRUC-2015
Monitoring Well
ID Well Tag Concrete Pad Comments
Groundwater Monitoring Wells
BG-1 Yes Yes
MW-1 Yes Yes
MW-2 Yes unknown
well buried under gravel, facility needs to unbury it
to check integrity of concrete pad
MW-3 Yes unknown
well buried under gravel, facility needs to unbury it
to check integrity of concrete pad
MW-4 No Yes needs permanent well tag
MW-5 No Yes needs permanent well tag
MW-6 Yes Yes
major erosion under concrete pad, pad needs
replacing
MW-7 No Yes
heavy vegetation surrounding well, vegetation needs
to be removed & needs permanent tag
MW-8 Yes Yes

Note: All wells should be labeled with reflective mailbox numbers/letters allowing proper
identification from a distance.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 5

Monitoring well has been buried under gravel, facility needs to unbury it to check integrity of concrete pad

16. At the time of the inspection, ash was being place in Subcells 2C and 2D. Interim soil cover has been
place on Subcells 1A & 1B and has been seeded.

Ash being placed in Cell 2C and 2D

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 5

17. Roadways are of all-weather construction. Where practicable, roadways are one-way to reduce
vehicular conflicts. A wheel washing station has been installed to reduce migration of coal
combustion products from truck traffic.

18. No windblown dust from operations or roadways was noted during the inspection.

19. Coal combustion products must not be placed in standing water. Surface water must be diverted
away from the operational area and must not be impounded over or in coal combustion products.
Water that comes into contact with coal combustion products shall be handled as leachate. No
standing water was observed on or adjacent to coal combustion products even though significant
rainfall had occurred a few days prior due to Hurricane Matthew. Preparations done onsite by the
site operators prior to the storm clearly helped minimize storm impacts at the site.

20. Two 500,000 gallon tanks have been installed onsite to hold leachate prior to offsite treatment. The
leachate tanks were observed during the inspection. Tank levels are checked by onsite staff on a
daily basis. During September 2016, a total of 1,810,859 gallons were pumped from the tanks.
During October 1 to October 10, a total of 640,239 gallons of leachate were pumped from the tanks.
Leachate is taken offsite for treatment or used within the footprint of the lined cells for dust control.

21. Storm water from the rail unloading yard is sloped to drain into an approximately 400,000-gallon
underground storage tank. The tank has the capacity to hold the run-off from a 25 year/24 hour
storm event. This water can be used for dust control on the lined area of the structural fill.

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

Phone: [phone]

Environmental Senior Specialist Regional Representative

Sent on:
October 20, 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
Shannon Aufman, Permitting Engineer, Solid Waste Section