9401_INSP_20170222

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

UNIT TYPE:
Lined
MSWLF LCID
T&P YW Transfer Compost SLAS COUNTY: Washington
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 9401-INDUS-2008
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill X DEMO SDTF FILE TYPE: COMPLIANCE

Date of Inspection: 22 February 2017 Date of Last Inspection: 7 July 2015

FACILITY NAME AND ADDRESS:
Domtar Paper Company Landfill
Ken Trowbridge Road
Plymouth, North Carolina

GPS COORDINATES: N: 35.84238 E: -076.77731

FACILITY CONTACT NAME AND PHONE NUMBER:
John Thomas Lilley
252.793.8825

FACILITY CONTACT ADDRESS:
Domtar Paper Company, LLC
PO Box 747
Plymouth, NC 27962
Attn: John Thomas Lilley
E-mail: [e-mail]

PARTICIPANTS:
Diane Hardison; Domtar Paper Company-Environmental Manager
John Thomas Lilley; Domtar Paper Company-Environmental Engineer
Ray Williams; NCDEQ-Solid Waste

STATUS OF PERMIT:
Active; Permit to Operate (PTO) Landfill 3 Phases 2, 3, and 4 issued 4 October 2013. This permit expires 22 May
2018. Pursuant to 15A NCAC 13B .0201(g) a complete permit review request including updated facility, operations,
and waste screening plans is due on or before 22 November 2017. This application must comply with the rules and
regulations in effect at the time of the application.

PURPOSE OF SITE VISIT:
Comprehensive Facility Compliance Inspection

STATUS OF PAST NOTED VIOLATIONS:
None applicable

OBSERVED VIOLATIONS:
1) 15A NCAC 13B .0201 (2)(g) states “All solid waste management facilities shall be operated in
conformity with these Rules and shall not create a nuisance, or an unsanitary condition, or a potential
public health hazard.”
2) 15A NCAC 13B .0503 (2)(c)(i) states “A site shall not cause a discharge of pollutants into waters of
the state that is in violation of the requirements of the National Pollutant Discharge Elimination
System (NPDES), under Section 402 of the Clean Water Act, as amended, or that is in violation of
standards promulgated under G.S. 143-214.1 and G.S. 143-215;”
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
9401_INSP_20170222
Page 2 of 6

3) 15A NCAC 13B .0503 (2)(c)(iii) states “A site shall not cause non-point source pollution of waters of
the state that violates assigned water quality standards.”
4) 15A NCAC 13B .1626 states “The owner or operator…must maintain and operate the facility in accordance with
the requirements set forth in this Rule and the operation plan as described in Rule .1625 of this Section.”
-DOMTAR PAPER COMPANY, LLC SOLID WASTE MANAGEMENT FACILITY PERMIT NO.
9401-INDUS-2008 Domtar Paper Company Landfill 3 ATTACHMENT 3 PART I: GENERAL
FACILITY (5) states “Facility construction, operations and/or practices must not cause or result in a
discharge of pollution…into waters of the state in violation of the requirements under Sections 401 and 404 of
the Clean Water Act, as amended.”

Please see the ADDITIONAL COMMENTS section below for details concerning the violations listed above.

ADDITIONAL COMMENTS:
1) This facility is permitted to receive solid waste generated by and on the property of Domtar Paper Company,
LLC and the Weyerhaeuser Plymouth Lumber Technology Facility located off of Ken Trowbridge Road,
Plymouth, North Carolina.
2) This facility is recorded with the Washington County Register of Deeds at: Book 443; Page 595.
3) This Facility is currently landfilling +/-5 tons of waste per day.
4) The certified operators for this Facility are as follows:
Kari Cahoon: Joyce Engineering North Carolina Certified Landfill Manager; expires 16 May 2020
5) A copy of the Facility Permit and Operations plan is maintained in the Facility Supervisor’s office. The
permit was in order and presented for review during this Facility Compliance Inspection.
6) Landfill gas monitoring is not required under the current PTO.
7) Groundwater monitoring is conducted semi-annually as required. All sampling is being conducted by
Environment One, Inc of Greenville, NC. The most recent event was conducted on 23 August 2016 and the
analytical report was submitted 28 September 2016. This report was in order and presented for review during
this Facility Compliance Inspection.
8) The current Financial Assurance document in the amount of $5,974,227.00 issued 29 April 2016 was
presented for review during this Facility Compliance Inspection.
9) This Facility screens all wastes received for unpermitted materials with one screening per week documented
in the waste screening log. This log was in order and presented for review during this Facility Compliance
Inspection.
10) The landfill supervisor conducts routine weekly maintenance inspections of the Facility and after every storm
event. These inspections are recorded in a log which was in order and presented for review during this Facility
Compliance Inspection.
11) Leachate is collected and treated on-site at the Domtar Paper Company Wastewater Treatment plant.
12) The Facility leachate collection and management system is being inspected as required. All leachate
collection system monitoring and maintenance activities are recorded in a dated log which is maintained in
the Facility Supervisor’s office.
13) The leachate system inspection log was in order and presented for review during this Facility Compliance
Inspection.
14) The leachate collection system is inspected internally bi-annually through pipeline video inspection and is
cleaned through power jetting as needed. All internal leachate system inspection and line jetting is conducted
by Jetclean America, LLC of Odessa, FL. The most recent inspection and jetting event was conducted in
April 2016.
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
9401_INSP_20170222
Page 3 of 6

15) Leachate sampling is being conducted semi-annually.
16) The leachate collection system cleanouts are highly visible, accessible, protected, and well maintained.
17) The Facility access road is of all-weather construction and is being maintained in overall good condition at
this time.
18) On 20 February 2017, a leak was discovered in the above ground portion of the leachate transfer line between
the landfill and the wastewater treatment plant. The facility leachate pumps were shut down and remained
offline until temporary repairs were made to the damaged line. The temporary repairs were observed during
this Facility Compliance Inspection and no leachate was observed leaking from the pipe. *Within thirty days
of receipt of this Facility Compliance Inspection Report, please submit a written plan for permanent repairs to
this damaged section of pipe.
19) Facility monitoring wells were reviewed during this Facility Compliance Inspection. All wells were readily
accessible, properly labeled, and secured with functioning locks.
20) Highly visible edge-of-liner stakes are being maintained throughout the Facility.
21) This landfill is currently operating in Unit III cell 2. Unit II Cell 1 has been closed and covered.
22) Phases 3 and 4 of the Landfill are currently being used for staging, screening, and processing ash from the
Domtar plant which is removed from the site for use as an agricultural soil amendment.
23) All ash processing and re-use operations are currently being managed by Advanced Residuals Management,
LLC of Fort Mill, South Carolina. Advanced Residuals Management personnel were on-site conducting ash
re-use operations during this Facility Compliance Inspection.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
9401_INSP_20170222
Page 4 of 6

24) The waste type in the landfill was reviewed; no unpermitted wastes were noted at the working face during this
Facility Compliance Inspection.
25) The working face is being maintained in a compact and manageable size.
26) Soil and ash are being stockpiled adjacent to the working face for daily cover.
27) Windblown debris is being well managed. Windblown debris was minimal and no windblown litter was
observed leaving the Facility during this Facility Compliance Inspection.
28) Overall, a cover crop of native warm season grasses has been well established and maintained on the closed
areas of the landfill. However, an area of sparse cover was observed near the top of the first lift at the
northwest corner of Phase 1 (please see the marked aerial photograph on page six of this report). *Please
grade, seed, and mulch this area to establish a groundcover suitable to prevent erosion of your landfill cap
system.
29) The Facility cover crop is mowed semi-annually.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
9401_INSP_20170222
Page 5 of 6

30) An area of leachate seepage was observed near the toe of the western sideslope of Phase 1 (please see the
marked aerial photograph on page six of this report). No leachate was observed leaving the permitted disposal
boundary. *Mechanisms should be installed to ensure that no leachate migrates outside of the permitted
disposal boundary. Within thirty days of receipt of this Facility Compliance Inspection Report, operations
should be underway for the repair of this area.
31) Areas of differential settlement were observed in several places near the lift two and lift three transition in
Phase 1. Some of these areas are restricting the flow of surface waters from the landfill (please see the marked
aerial photograph on page six of this report). *Plans need to be underway for the filling and grading of these
areas to promote the positive flow of surface waters from the landfill.
32) The stormwater/sedimentation control basins were clear of excess sedimentation and woody vegetation and
appear well maintained at this time.
33) The surface water drainage features are well maintained, in good working order, and appear to be functioning
properly.
34) No off-site erosion was observed during this Facility Compliance Inspection.
35) *Corrective measures are required as a result of this Facility Compliance Inspection.

Please contact me if you have any questions or concerns regarding this Facility Compliance Inspection Report.

Ray Williams; Environmental Senior Specialist Phone: [phone] E-mail: [e-mail]

Regional Representative

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Delivered on: 2 March 2017 by Electronic delivery US Mail X Certified No. [7015 0640 0005 9080
7389]

cc: Andrew Hammonds; Eastern District Supervisor/SWS: [e-mail]
Jessica Montie; Chief Compliance Officer/SWS: [e-mail]

C: \2017\Washington\Facilities\94-01\Inspections\9401_INSP_20170222
NCDEQ DWM Laserfiche Online Document Management System: http://edocs.deq.nc.gov/WasteManagement/Welcome.aspx

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Approximate area of observed sparse cover marked with white arrow. 
Approximate area of observed leachate seep marked with red arrow. 
Approximate area of observed standing water marked with yellow arrow.