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HomeMy WebLinkAbout3420_INSP_20170713FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 8 UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Forsyth Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 34-20 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill X DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: July 13, 2017 Date of Last Inspection: August 11, 2015 FACILITY NAME AND ADDRESS: OmniSource Southeast Industrial Landfill 1426 W. Mountain Street Kernersville, NC 27284 GPS COORDINATES: N: 36.142173° W: -80.102696 ° FACILITY CONTACT NAME AND PHONE NUMBER: Name: James Winegar, Environmental Manager Telephone: (919) 796-3023 (mobile) Email address: jwinegar@omnisourcese.com FACILITY CONTACT ADDRESS: James Winegar, Environmental Manager OmniSource Southeast 2233 Wal-Pat Road Smithfield, NC 27577 PARTICIPANTS: James Winegar, Environmental Manager – OmniSource Southeast Scott McDaniel, Regional Manager – OmniSource Southeast Chris Perry, Site Manager – Second Pass LLC Ming-Tai Chao, Permit Engineer – Solid Waste Section Perry Sugg, Permitting Hydrogeologist – Solid Waste Section Susan Heim, Environmental Senior Specialist – Solid Waste Section STATUS OF PERMIT: Permit to Operate Auto Shredder Residue Reclamation Operation issued to Atlantic Scrap and Salvage LLC: 9/2/2005. Permit to Operate Expired: 9/2/2008. Permit Application for OmniSource Southeast submitted: 5/27/2014; in review process – no renewal permit issued. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: N/A OBSERVED VIOLATIONS: None 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 2 of 8 ADDITIONAL COMMENTS 1. The facility was originally permitted under Atlantic Scrap and Processing LLC to operate an auto shredder residue (ASR) reclamation operation, removing waste from the existing ASR industrial landfill and processing it to recover metals and returning the residual material to the landfill. 2. Atlantic Scrap and Processing LLC was acquired by OmniSource Southeast, who now owns and operates the facility. OmniSource has contracted with Second Pass LLC to process the ASR from the landfill. OmniSource has been actively working with Permitting Branch staff to acquire a new permit for the facility in their name. 3. The landfill is located on the northern end of the OmniSource Kernersville facility, and is secured by the same means used to secure the entire property – fencing and gates. The landfill is accessed through the main gate that is locked except during business hours. Signage was observed at the facility entrance. 4. The facility was originally permitted to handle and process only materials recovered from the ASR landfill and only the residual from these operations was allowed to be returned to the landfill for disposal. Mr. McDaniel stated that OmniSource maintains a strict separation between the landfill operations and the salvage yard operations; and, any residual materials generated by the scrap yard are transported offsite for additional processing or sent to a permitted facility for disposal. 5. Mr. Perry explained that all of the landfilled material had now been processed and returned to the fill area, with the exception of a single large pile of processed material that had been staged on top of the landfill pending additional processing. He stated that new equipment had been developed and installed that enables an additional recovery rate of approximately 6% (metals) from the processed material that had already been returned to the landfill. Mr. Perry stated that this new process had been operating for several months, and that OmniSource and Second Pass had evaluated the results and concluded that it would be financially efficacious to continue reprocessing the material from the landfill. 6. The most recently submitted revised Operations Plan, dated August 2016, was available for review. Mr. Chao reported that he had not found any such revisions nor any indication that they had been received by the Solid Waste Section. Mr. Winegar stated that this information had been submitted to Permit Engineer John Murray on two separate occasions. He added that the revised submittal is now out of date, since the original reclamation operation has been completed and the processing equipment associated with it is no longer in use. He added that the 2016 submittal did not include the new operations that are currently underway, including a new recovery process with new equipment. 7. Groundwater monitoring has been taking place as required on a semi-annual basis, as indicated by the reports on file. Records for the two semi-annual sampling events for 2016, performed April 12, 2016 and October 12, 2016, were reviewed and verified. The October event included samples from the two new surface water monitoring points that were added as requested by the Solid Waste Section. 8. Operations records were reviewed. Mr. Perry stated that he keeps track of the material removed from the landfill for processing and the material returned to the landfill for disposal on a daily basis. Mr. Winegar explained that he compiles the tonnage records into monthly totals, for use in producing the annual facility report. He provided a copy of the tonnage records for the period July 2015 through June 2017 via email following the inspection. A review of these records revealed the following totals for this time period: 272,229 tons of material were removed from the landfill unit for processing; 18,367 tons of material were recovered during processing; and, 253,862 tons of residual waste were returned to the landfill for disposal. 9. The landfill area is accessed from the southern side, where the top of fill is close to the grade level of the surrounding area. To the west, a perimeter road has been established that leads around the landfill to the north side, where the fore bay and sediment pond below it are located. The perimeter road is constructed of compacted soil and processed residual ASR material, and is maintained to a size that permits dump trucks and heavy equipment to operate safely on it. 10. The disposal area had been completely refilled with processed residual waste except for the final cell on the eastern boundary of the landfill unit. Several small pools of water were observed in this area. Mr. Perry stated that the water would continue to be absorbed into the waste and remain inside the landfill, as required. 11. The new processing equipment uses water to separate materials by weight. This process generates “heavies,” which are metals; soil, which can be used elsewhere on the property; and, “lights,” which are residual waste materials that are returned to the landfill for disposal. Mr. Perry explained that this process does not require the FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 8 use of the hot air dryers that were integral to the previous processes. He added that all water used in the separation of these materials is recycled. The used water is directed to one of the large holding tanks, where sediment settles and is removed when the tank is periodically cleaned. It appears that the three process streams yield end products that are wet. Please provide information as to how the liquid generated at the end of the processing line is captured and managed. 12. A stockpile of ASR material is located in and around the covered storage area near the new processing equipment. Mr. Perry indicated that the stockpiled is stored on a pad. He stated that enough material was stockpiled to feed the processing line for approximately 4 to 5 days. 13. The access road is bordered by silt fencing on the west shoulder. One small area of silt fence appeared to be in need of maintenance that would anchor it to the ground and ensure that silt and sediment do not leave the landfill area. Ensure that the silt fence is anchored and functioning properly. 14. Edge of waste markers were installed around the waste disposal area; however, after discussions with Mr. Perry and Mr. Winegar, it was unclear as to whether or not they had been accurately placed. The perimeter roadway sits on top of and is composed party of ASR waste. It is therefore assumed that the roadway would be located inside of the waste boundary. Mr. Winegar and Mr. McDaniel stated that they would consult with their engineer about this matter and provide additional information as to whether or not the markers need to be relocated. Please note that waste must be disposed of inside the landfill footprint. Any determination about waste placement must be reserved until current information is provided in an updated Operations Plan and permit application. Additional action may be required after a review of that information is completed. 15. It is suggested that the permanent edge of waste markers be raised and/or painted so that they are easily visible and readily identifiable. 16. A review of facility records revealed that a diversion berm had been constructed on the west side of the landfill, stretching around the northern side. The berm was to have been constructed of clean earthen material. The purpose of the berm was to ensure that no waste material from the fill area was allowed to leave the footprint of the landfill. Based on observations made during the inspection, it appears that the berm is no longer functioning as designed. ASR material was observed beyond the silt fencing on the western side of the landfill. Please provide information about the actual location of the western berm, and ensure that repairs are made to enable it to function as designed. 17. According to site plans records, a number of catch basins had been constructed around the western perimeter of the landfill. During this inspection, only one catch basin was observed in this area. Please provide information as to the location and condition of all catch basins associated with the landfill reclamation operation. 18. Surface water on the eastern portion of the site is currently being directed to a drainage ditch containing a series of check dams designed to slow the flow of the water. The ditch is located to the east of the landfill and runs north along the perimeter of the fill area to the fore bay, where it enters slope drains that empty into the sediment pond below. 19. Mr. Perry stated that stormwater that falls inside the disposal boundary remains in the landfill and is absorbed into the waste. He explained that the ASR reacts in a manner similar to that of a sponge, so that water runoff leaving the landfill footprint is not an issue. 20. A berm separates the fill area from the drainage ditch on the east side of the landfill. In several areas, waste appeared to be approaching the level of the top of the berm. Ensure that excess waste is removed from this area so that the berm functions properly, keeping waste from entering the drainage ditch. 21. It appears that this berm may be constructed of waste from the fill area. Please provide clarification about the construction and purpose of the berm. 22. Some portions of the drainage ditch near the northeastern end of the landfill appeared to be eroded and clogged with weeds and vegetation. Perform maintenance on the drainage ditch to ensure that it functions properly, with adequate depth and a clean path in which water may flow. 23. The fore bay is located on the north side of the facility near the toe of the landfill. There appears to be no separation between the disposal area and the fore bay, so any liquid leaving the landfill would travel directly to the fore bay. 24. The sediment pond contains a curtain boom, presumably designed to ensure that sediment does not leave the pond. However, sediment was visible on the spillway at the western end of the pond. Remove sediment from the spillway and return it to the landfill for proper disposal. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 8 25. Beyond the sediment pond, a rip-rapped swale leads downhill to a flat, cleared area. Sediment was visible in the rip-rap of the swale at the time of the inspection. Remove sediment from the spillway and return it to the landfill for proper disposal. 26. Records indicate that a rock dam had been constructed at the bottom of the swale to trap any sediment contained in the runoff from the pond. However, no erosion control devices were observed at the bottom of the swale or in the cleared area that would contain or control any runoff directed to this point. No ponded liquid was observed in this area at the time of the inspection; however, the ground was moist. Please provide information about the erosion and sedimentation control measures in place for this area. 27. A pile of debris was observed to the west of the sediment pond. Mr. Perry stated that the debris was material that had been removed from the sediment pond when it was cleaned earlier in the year. Ensure that this waste is removed and properly disposed of within the landfill. 28. The expired permit, originally issued in 2005, and the approved Operations Plan, dated February 2005, do not reflect or address the current site conditions and operations. Based on a review of facility records and observations made during the inspection, it is difficult to understand the stormwater and leachate collection systems and how they function. Please provide detailed information about the separation and management of stormwater and leachate at the landfill facility. 29. After some discussion, Mr. McDaniel and Mr. Winegar stated that they felt it that a revised Operations Plan and permit application could be submitted to the Solid Waste Section within a few weeks. A deadline of August 31, 2017 was agreed to by all parties present. 30. Ensure that a revised Operations Plan and permit application are submitted to Ming-Tai Chao, Permitting Engineer, no later than August 31, 2017. View of the southern edge of the fill area, with the new processing equipment and stockpile areas in the background. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 8 View of the fore bay from the northern toe of the landfill. Note 3 slope drains leading to the sediment basin below. Water from the eastern perimeter drainage ditch enters the fore bay at the far right. View of sediment basin from fore bay, above, with slope drains carrying liquid from fore bay. Note curtain boom in the pond and sediment on spillway to the west of the basin. The rip-rap swale leads downhill to a flat, open area with no erosion control devices. Liquid entering this area disperses naturally or is absorbed into the soil. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 8 View of the eastern side of the landfill with a berm and drainage ditch. Note waste approaching the top of the berm. View of the eastern perimeter drainage ditch near the northeastern slope of the landfill. Note erosion and vegetation impeding the drainageway. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 8 New processing line in operation. The three processed streams can be seen at center; water tanks at right; a portion of the stockpile area with conveyor feed at left. Note liquid generated along with processed materials. View of the southeastern corner of the landfill. A distinct line is visible between the layers of waste and soil. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 8 Please contact me if you have any questions or concerns regarding this inspection report. ________________________________________ Phone: 336-776-9672 Susan Heim Environmental Senior Specialist Regional Representative Sent on: July 20, 2017 to James Winegar. X Email Hand delivery US Mail Certified No. [ ] Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Deb Aja, Western District Supervisor - Solid Waste Section Jessica Montie, Compliance Officer – Solid Waste Section Jaclynne Drummond, Compliance Hydrogeologist – Solid Waste Section Ming-Tai Chao, Permitting Engineer – Solid Waste Section Ed Mussler, Permitting Branch Head – Solid Waste Section Perry Sugg, Permitting Hydrogeologist – Solid Waste Section Scott McDaniel, Regional Manager – OmniSource Southeast Chris Perry, Site Manager – Second Pass LLC