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HomeMy WebLinkAbout7602_EnergizerBattery_20170421_INSPFACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 5 UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Randolph Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 76-02 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill X DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: April 21, 2017 Date of Last Inspection: April 13, 2016 FACILITY NAME AND ADDRESS: Energizer Manufacturing, Inc. Industrial Landfill County Land Road Randleman, NC 27317 GPS COORDINATES: N: 35.75136 W: -79.76899 FACILITY CONTACT NAME AND PHONE NUMBER: Scott Boyle, Staff Environmental Coordinator Asheboro Facilities – Energizer Household Products w. 336-672-4546 c. 336-736-2278 scottv.boyle@energizer.com FACILITY CONTACT ADDRESS: Energizer Household Products Scott Boyle, Staff Environmental Coordinator 419 Art Bryan Drive Asheboro, NC 27203 PARTICIPANTS: John Patrone, Environmental Senior Specialist - Solid Waste Section (SWS) Scott Boyle, Staff Environmental Coordinator Asheboro Facilities – Energizer Household Products Julia Bowman, Environmental Assistant Asheboro Facilities – Energizer Household Products STATUS OF PERMIT: Permit To Operate (PTO) issued August 23, 2012 PTO expiration date August 23, 2017 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 On April 21, 2017, John Patrone met with Scott Boyle and Julia Bowman to conduct a comprehensive inspection of the Energizer Manufacturing, Inc. Industrial Landfill on County Land Road in Randleman, Randolph County. 1. The industrial landfill is located on property owned by Energizer Manufacturing, Inc. 2. Access to the landfill is via the Randolph County Solid Waste Facility located at 1254 County Land Road (follow gravel road past transfer station 76-03, take first right). 3. The facility is permitted to accept scrap batteries from the battery manufacturing process located at the Energizer Manufacturing, Inc. plant in Asheboro, North Carolina. 4. The landfill is not currently in operation. Mr. Boyle stated that scrap batteries have not been placed in the landfill since ~ 2010. 5. Mr. Boyle stated that Energizer Manufacturing, Inc. would like to maintain an active facility permit in case the landfill is used in the future. 6. Mr. Boyle stated that Energizer Manufacturing, Inc. might mine the landfill in the future. The mined material can be used in the production of recycled batteries. If the landfill is to be mined, ensure the SWS – Permitting Branch is notified prior to mining activity. 7. The industrial landfill consists of Phases 1, 2, and 3A. Phase 1 is closed, Phase 2 contains intermediate cover, and Phase 3A has been constructed. 8. Phase 3A has been constructed atop Phase 1. It has not been used to date. 9. In the future, Phase 3 will extend atop Phases 1 and 2. 10. Phases 1 and 2 are clay-lined and Phase 3 contains a synthetic liner. A 60-mil HDPE temporary berm flap has been installed along the northern perimeter of Phase 3A (future Phase 3B tie-in). 11. Phases 1, 2, and 3 each have a leachate line clean-out access pipe(s). 12. The facility site plan, permit, and operations plan were discussed. 13. Mr. Boyle stated that if the landfill were to operate it would be contracted to a third-party to manage. 14. The facility annual report (FAR) dated July 12, 2016 was received by the SWS. Facility throughput for July 2015 through June 2016 is 0.00 tons. 15. The facility is permitted to use a tarp as alternative daily cover. 16. The facility has three groundwater monitoring wells: MW-1A, MW-2A, and MW-3A. The groundwater monitoring wells were observed. 17. The facility maintains semiannual groundwater monitoring records prepared by Pyramid Environmental & Engineering, PC., analyzed by ESC Lab Sciences. Records for groundwater monitoring conducted on August 25, 2016 and February 7, 2017 were verified. An exceedance is noted for each sampling event. 18. The facility has a stormwater National Pollutant Discharge Elimination System (NPDES) permit, General Permit No. NCG120000. The NPDES permit was issued November 1, 2012 and expires October 31, 2017. 19. Leachate from Phases 1 and 2 is piped to two underground storage tanks/manholes. 20. The leachate from Phase 1 collects in storage manhole number 1 and leachate from Phase 2 collects in storage manhole number 2. 21. Mr. Boyle stated that each storage manhole is ~ 3,500 gallons. 22. Two smaller tanks have been installed to collect the leachate from Phase 3A. The tanks currently collect stormwater that is piped to discharge. When Phase 3A is operational the discharge pipe will be capped. 23. Leachate manholes 1 and 2 are routinely pumped-out. 24. The leachate from manhole number 1 is pumped-out by facility personnel into two 22,000 gallon frac tanks stored on site. 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 25. The two frac tanks and leachate manhole number 2 are pumped-out by Shamrock Environmental Corporation. Mr. Boyle stated that the leachate is hauled to the Shamrock Environmental Corporation’s treatment facility in Guilford County. 26. The facility maintains a leachate manhole and frac tank pump log. The pump log includes: manhole inspection date, manhole pump date, volume transferred to frac tanks, and volume pumped-out for removal. Records were verified for May 6, 2016 through April 20, 2017. 27. The leachate manholes are checked by facility personnel twice a week and after an inclement weather event. Mr. Boyle stated that the manholes are not checked daily because the landfill is not in operation. 28. When the facility permit is updated or modified the frac tank leachate storage process should be included in the operations plan. Contact Ming-Tai Chao, Environmental Engineer – SWS at 919-707-8251, for further discussion. 29. Leachate shall be tested semiannually prior to being hauled-off site. Leachate shall be tested concurrently with groundwater sampling. 30. The facility maintains semiannual leachate testing records prepared by Pyramid Environmental & Engineering, PC., analyzed by ESC Lab Sciences. Records for leachate testing conducted on August 25, 2016 and February 7, 2017 were verified. 31. The landfill cap appeared maintained and in good condition. 32. The landfill cap contains a vegetative cover layer of grass. Mr. Boyle stated that the landfill cap is routinely mowed. 33. No erosion of runoff was observed. 34. Edge of waste markers (signs) have been installed. 35. The City of Asheboro Fire Department can be contacted to respond to an emergency. 36. The facility is secured by a locked gate. 37. Access roads are of all-weather construction. 38. The facility has proper signage. 39. The PTO expiration date is August 23, 2017. 40. Mr. Boyle stated that the facility renewal application will be submitted to the SWS in the coming days. Please contact me if you have any questions or concerns regarding this inspection report. Phone: 336-776-9673 John Patrone Environmental Senior Specialist Regional Representative Sent on: April 24, 2017 X Email Hand delivery US Mail Certified No. [ _] Copies: Deb Aja, Western District Supervisor - SWS Jessica Montie, Compliance Officer – SWS Ming-Tai Chao, Environmental Engineer – SWS Ervin Lane, Compliance Hydrogeologist – SWS Steve Hall, Facility Manager Asheboro Facilities – Energizer Household Products (w. 336-672-4501, stevet.hall@energizer.com) Julia Bowman, Environmental Assistant Asheboro Facilities – Energizer Household Products (w. 336-672-8727, juliau.bowman@energizer.com) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 5 Digital pictures taken April 21, 2017 by John Patrone, DWM – SWS Phase 3A constructed atop Phase 1 Phase 3A - future Phase 3B tie-in (temporary berm flap) Phase 2 – intermediate cover Phase 1 side slope – representative FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 5 Phase 2 side slope – representative Phase 3A side slope – representative Phase 1 leachate manhole – stationary mechanical pump Phase 2 leachate manhole Phase 3 leachate storage tanks (future use) Phase 1 leachate storage - frac tanks