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Home My WebLink About1910_Brickhaven_INSP_20170405FACILITY 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: April 5, 2017 Date of Last Inspection: October 11, 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: Thomas (Tom) Flannagan, Project Director, Direct: 704-985-2992, tflannagan@charah.com FACILITY CONTACT ADDRESS: Green Meadow, LLC 352 Brickyard Road Sanford, NC 27330 (877) 314-7724 PARTICIPANTS: Shawn McKee, NCDEQ, Solid Waste Section Elizabeth Werner, NCDEQ, Solid Waste Section Shannon Aufman, NCDEQ, Solid Waste Section Mary Whaley, NCDEQ, Solid Waste Section Tom Flannagan, Charah, Inc. Jeremy Kerly, Charah, Inc. 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. 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. 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. 3. A sign providing the facility name, permit number, operating hours, and emergency contact numbers is posted at the site entrance. 4. A responsible individual trained in operations must be on-site at all times during all operating hours. The following personnel are Certified Landfill Managers for North Carolina: Jacob Buda, 16-0M-00174, exp. 5/20/19 Ronald Berryhill, 16-02M-0164, exp. 5/20/19 Rebecca Carrington, 16-02M-00171, exp. 5/20/19 Jeff German, 16-02M-00175, exp. 5/20/19 Nathan Nickerson, 13-02M-0074, exp. 7/24/19 Adam Piacentino, 16-02M-0172, exp. 10/14/19 Thomas Wells, 16-02M-0172, exp. 5/20/19 5. 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 March 7, 2017. 6. The structural fill began placing coal combustion products on October 23, 2015. At the time of the inspection, trains were operating as normal. During normal operations, approximately one or two trains 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 45 trains total). 7. As of the date of the inspection, 3,529,403.06 tons of CCPs have been placed within the structural fill. Of that total tonnage, 3,503,102.97 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. 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 5 8. 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. 9. 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 were reviewed during the inspection. 10. 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. 11. 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. 12. 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. 13. 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 Yes Well pad intact and visible. Recommend marking with “MW-2” on side of well casing for visibility. MW-3 Yes Yes Well pad intact and visible MW-4 Yes Yes permanent well tag has been affixed MW-5 Yes Yes permanent well tag has been affixed. Check periodically for erosion near the pad so that the pad does not get buried. MW-6 Yes Yes Well pad has been repaired. Recommend marking with “MW-6” on side of well casing for visibility. MW-7 Yes Yes vegetation surrounding well has been mowed, permanent well tag has been affixed. Well being replaced in mid-April to an adjacent location. MW-8 Yes Yes Recommend marking with “MW-8” on side of well casing for visibility. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 5 Monitoring well - MW-4. Properly labeled, protected and maintained. 14. At the time of the inspection, ash was being place in Subcells 2A and 2B. Cell 2B was approximately 90% filled. Cells 2E, 2F, and 2G were under construction and ready for liner. Ash being placed in Cells 2A and 2B FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 5 15. 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. 16. No windblown dust from operations or roadways was noted during the inspection. 17. 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. 18. 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. An average of between 100,000 and 120,000 gallons a day are pumped from the tanks and trucked to wastewater treatment plants permitted to accepted the leachate. Leachate is taken offsite for treatment or used within the footprint of the lined cells for dust control. 19. 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: 919-707-8284 Environmental Senior Specialist Regional Representative Sent on: April 18, 2017 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