3406_NOD_20180713

July 13, 2018

CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7011 1570 0001 8545 5998

Mr. Alexander Lacsamana
District Manager
Closed Site Management Group
Waste Management, Inc.
1000 Parkwood Circle, Suite 700
Atlanta, GA 30339

SUBJECT: Notice of Deficiency
Compliance Inspection Report
Piedmont Landfill
Permit Number 34-06
Forsyth County

Dear Mr. Lacsamana:

On July 3, 2018, Christine Ritter, Hydrogeologist with the Solid Waste Section Environmental
Compliance Branch, received notification via electronic correspondence from Van Burbach,
Senior Technical Consultant, Joyce Engineering, Inc. on behalf of Waste Management, Inc., of a
leachate release at the Piedmont Landfill located in Kernersville, Forsyth County, North Carolina.
Mr. Burbach reported that the release was discovered on Friday afternoon, June 22, 2018, during
a routine inspection of the facility at a leachate cleanout along the side of Freeman Road. The
leachate cleanout was found to have been sheared off and was slowly leaking around an
attempted plug of the 6-inch HDPE cleanout pipe. Leachate-saturated soils were observed
around the cleanout. The leachate sumps at the facility were reported to be turned off
immediately and the pipe was temporarily capped. It was further reported that repairs to the
cleanout were completed on June 26, 2018.

Based on the Section’s review of the information provided to date, there is no indication that an
action taken and/or not taken by Waste Management, Inc. directly lead to the release of leachate
at this time, however the following violation shall be noted:

A. 15A NCAC 13B .1604(b)(2)(L)(iii) states that: The permittee shall report orally within 24
hours from the time the permittee becomes aware of the circumstances of any release or
discharge outside the liner, collection system or other containment component, any fire, or
explosion from the permitted landfill facility. Such reports shall be made to the Division
representative at the appropriate regional office of the Department of Environment and
Natural Resources.

The above violation may have or can compromise the facility’s ability, and the Department’s
regulatory authority over the requirements of a response action, to ensure protection of the
public health and the environment. In order to resolve any outstanding issues related to the
leachate release, Waste Management, Inc. must take the following actions by the timeframe
specified below or by no later than 10 days of receipt of this Notice of Deficiency:

1. Implement the Leachate Release Assessment Sampling Plan dated July 11, 2018 as
approved by Christine Ritter, Hydrogeologist on July 12, 2018. The plan must be
implemented within 7 days of Ms. Ritter’s approval with documentation detailed in Ms.
Ritter’s email dated July 5, 2018 within 10 days after receipt of analytical results from the
laboratory.
2. Submit a detailed written response to Ming-Tai Chao’s email dated July 6, 2018 regarding
data to document status of the proper functioning of leachate collection system. The
submittal shall provide leachate generation and disposal volumes data for each leachate
pump from the date of the site closure to present.
3. Submit a detailed written description, including waste disposal receipts, etc., of where
any excavated soils have been stockpiled and their final disposition.
4. Submit a detailed written description of any impacts to the adjacent Kernersville Landfill
facility, located adjacent to the leachate cleanout along Freeman Road.

Waste Management, Inc. shall provide a written certification with supporting documentation on
company letterhead confirming the noted compliance schedule has been completed. Include in
this certification any actions taken to prevent these violations from occurring in the future. Email
this certification to Susan Heim by no later than 10 days of receipt of this Notice of Deficiency.

The violation listed above requires action on behalf of the Waste Management, Inc. 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.

Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct
a follow-up inspection(s) to verify that the facility has completed the requirements of this Notice
of Deficiency.

If you have any questions please contact me at 336-776-9672, or via e-mail at
[e-mail].

Sincerely,

Susan Heim
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section

copies: Ed Mussler, Solid Waste Section Chief
Jason Watkins, Field Operations Branch Head
Adam Ulishney, Environmental Compliance Branch Head
Sherri Stanley, Permitting Branch Head
Deb Aja, Western District Supervisor
Christine Ritter, Hydrogeologist – Environmental Compliance Branch
Ming-Tai Chao, Environmental Engineer – Permitting Branch
Van Burbach, Senior Technical Consultant – Joyce Engineering, Inc.