4204_INSP_20161201

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: December 1, 2016 Date of Last Inspection: June 2, 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:
Shawn McKee – NCDEQ, Solid Waste Section
Shannon Aufman – NCDEQ, Solid Waste Section
Ed Stanfield, Halifax County, Landfill Supervisor
Greg Griffin, Halifax County, Director of Public Utilities

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.”

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 had soil cover placed, and been graded and mulch as of the December 1, 2016 inspection. Vegetative cover
should be established to prevent erosion. (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 had soil cover placed, and been graded and mulch as of the December 1, 2016 inspection. Vegetative
cover should be established to prevent erosion. (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 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 operating
infrequently, 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. Between July 1, 2015 and June 30, 2016, a total of 6,799.43
tons of coal combustion residues were disposed of at the landfill.

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

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

6. Edge-of-waste markers were in place and being maintained at the time of the inspection.

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

7. 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. Conditions during the inspection were breezy and dry but dusting was not observed.

8. 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. Cover has also been placed on the western slope with mulch for temporary stabilization.
(identified as Sequence No. 3B in the Cover Plan). The northeastern slope has been reworked to better utilize
permitted airspace. The facility plans to place intermediate cover in this area next. Other slopes have been
regraded to reduce erosion. Continue to place intermediate cover on all slopes in accordance with the
approved Cover Plan.

Northeastern slope Recently covered western slope.

9. Because the southern slope does not have intermediate cover, ash migrating to the toe of the slope during heavy
rains continues to be a problem. Facility staff return ash to the slopes and regrade after each heavy rain.

Southern slope.

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

10. 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.”

11. 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:
December 15, 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, Engineering Project Manager, Solid Waste Section