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Home My WebLink About1910_Brickhaven_INSP_20180305FACILITY 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: March 5, 2018 Date of Last Inspection: June 22, 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, 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 Laura Leonard, NCDEQ, Division of Waste Management Tracey Holloway, NCDEQ Tom Flannagan, Charah, Inc. Nathan Nickerson, Charah, Inc. Jeremy Kerley, 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. The following personnel are Certified Landfill Managers for North Carolina:  Tom Flanagan, 11-02M-00019, exp. 3/16/20  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  Thomas Walls, 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 January. 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 current operations, approximately 20 trains per month of coal combustion products (CCPs) arrive from the Duke Energy Riverbend Steam Station (approximately 45 trains total). As of late June 2017, ash was no longer being received 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 3/4/18, 6,088,202 tons of CCPs have been placed within the structural fill. Of that total tonnage, 6,061,901.91 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 8,500 to 8,800 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, 2016 and June 30, 2017, the facility reported that 3,188,558 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 for review to the Solid Waste Section. Active ash placement area FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 5 13. 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. Monitoring wells observed during the inspection were being properly maintained. 14. At the time of the inspection, ash was being placed in cells 2E and 2 F. Cells 2A and 2B are complete and are capped, bermed and have downslope drains to prevent erosion. 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. Site conditions were sunny and dry at the time of the inspection. 17. 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. 18. 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: March 19, 2018 Email: X Hand delivery US Mail Certified No. [ _] Copies: Ed Mussler, Section Chief, 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