1910_INSP_20170622

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: June 22, 2017 Date of Last Inspection: April 5, 2017

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, [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
Ethan Caldwell, NCDEQ, Solid Waste Section
McKenzie Bradford, NCDEQ, Solid Waste Section
Marissa Nixon, NCDEQ, Solid Waste Section
Tom Flannagan, 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 and complaint follow-up.

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. Tom Flanagan is a Certified Landfill Operator, Cert. 73270, exp. 7/28/18.

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
 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 facility conducts weekly inspections. These were reviewed during the inspection.

7. 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). As of the end of June 2017, ash will no longer be coming from the Sutton Steam
Plant.

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. As of the date of the inspection, 4,212,557.01 tons of CCPs have been placed within the structural
fill. Of that total tonnage, 4,186,256.92 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.

9. 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.

10. 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.

11. 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.

12. 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.

Ash being placed in Cell 2A

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

13. Almost 1 inch of rain had been received at the facility prior to the inspection. Rainfall is monitored
onsite daily and is recorded in the facility records. Additional berming and grading had been done
prior to the rain even to facilitate the flow of leachate into the leachate collection system.

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. MW-7 has been replaced with MW-7R.

16. At the time of the inspection, ash was being place in Subcells 2A and 2B. Cells 2E, 2F, and 2G were
nearing completion and will be filled in the following order: 2G, 2F, 2E.

17. Closure of Cell 1 was nearing completion.

18. 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.

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

20. Three 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.

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:
July 17, 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