6401_INSP_20190123

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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
X
Transfer
Compost
SLAS
COUNTY: Nash
MSWLF
PERMIT NO.: 6401-MSWLF-1983
Closed
X
HHW
White
X
Incin
T&P
FIRM
MSWLF
goods
6401-CDLF-1999
6403-CDLF-2000
DS64-006
FILE TYPE: COMPLIANCE
CDLF
X
Tire T&P/
X
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: January 23, 2019 Date of Last Inspection:
FACILITY NAME AND ADDRESS:
Nash County C&D Landfill
SR 1425
3057 Duke Rd.
Nashville, NC 27856
GPS COORDINATES: N:36.05918 ° E: - 78.00552 0
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Ben Barnes and Matthew Richardson
Telephone: [phone] (Barnes cell 252-904-3396)
Email address: solidwaste(knashcountync.gov; Matthew.Richardson(c-r�,nashcountync.gov
FACILITY CONTACT ADDRESS:
Nash County Solid Waste
P.O. Box 849
Nashville, NC 27856
PARTICIPANTS:
Davy Conners, NC DEQ
John College, NC DEQ
Ben Barnes, Nash County
Matthew Richardson, Nash County (present for records review)
STATUS OF PERMIT:
6401-MSWLF-1983 (Closed): The MSWLF ceased accepting waste during the summer of 1998, closure was
documented in a CQAR prepared by GEI Consultants and dated December 1998.
640 1 -CDLF- 1999 (Closed): Located on top of the closed MSWLF landfill (6401-MSWLF-1983), construction and
demolition waste material was accepted until 2000, final closure was documented in a CQAR prepared by GEI
Consultants and dated March 2000.
6403-CDFL-2000: Permit to Construct Phases 5-9 and Permit to Operate Phases 1-4 was issued October 24, 2018, and the
estimated life of the landfill is approximately through 2053.
DS64-006: Activated September 13, 2018, must be deactivated by March 13, 2019.
PURPOSE OF SITE VISIT:
Comprehensive Compliance Inspection
STATUS OF PAST NOTED VIOLATIONS:
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FACILITY COMPLIANCE INSPECTION REPORT
E� Division of Waste Management
Solid Waste Section
OBSERVED VIOLATIONS:
Per 15A NCAC 13B .1627 (d)(1), "Following closure of each MSWLF unit, the owner or operator shall conduct
post -closure care... (which) consists of at least the following: (A) Maintaining the integrity and effectiveness of any
cap system, including making repairs to the cover as necessary to correct the effects of settlement, subsidence,
erosion or other events and preventing run-on and run-off from eroding or otherwise damaging the cap."
And per 15A NCACI3B .1626 (8)(b), "Surface water shall not be impounded over or in waste"
Nash County is in violation of the above rules in that, during the inspection, two areas of the closed MSW landfill
were observed with water ponding over waste. These areas, located along the north slope near the top and along the
southwestern slope about half way down, also had wetland vegetation, indicating that standing water is frequently an
issue. Within 30 days of this report, the specified areas of subsidence and impoundment must be repaired. Areas of
subsidence should be attended to on a continuing basis.
Water impounding over waste at the closed MSWLF
Per 15A NCAC 13B .1627 (d)(1), "Following closure of each MSWLF unit, the owner or operator shall conduct
post -closure care... (which) consists of at least the following... (B) Maintaining and operating the leachate
collection system in accordance with the requirements in Rules .1642 and .1626."
And per 15A NCACI3B .1626 (8)(d), "Leachate shall be contained within a lined disposal cell or leachate collection
and storage system."
Nash County is in violation of the above rules in that leachate was observed seeping from the landfill and flowing
into a drain pipe. The seep is located near the north east corner of the landfill, close to the top. It is just below the area of
impounded water (noted above); this water is likely the cause of the leachate seep.
The County plugged the leachate seep on the same day as the inspection and sent photo evidence of the work
done (see below).
Within 7 days of this report, the County must investigate and notify the Section of the location of the drain
pipe's outlet and where it flows to. If the outlet is outside the waste boundary and/or flows into a ditch, line, sediment
basin, or into surface water, then environmental sampling will be necessary, and it may lead to a Notice of Violation or
further enforcement action.
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FACILITY COMPLIANCE INSPECTION REPORT
�DK Division of Waste Management
Solid Waste Section
Leachate seep on top of closed MSnF
;a_ AL -ALL
#
Photo provided by Nash County of the dirt plug used to stop the leachate seep.
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.
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FACILITY COMPLIANCE INSPECTION REPORT
�DK Division of Waste Management
Solid Waste Section
ADDITIONAL COMMENTS
The following observations were made during the January 23, 2019 inspection. Please resolve all compliance issues
(noted in bold) within 30 days of this report.
6401-MSWLF-1983 and 6401-CDLF-1999:
Closed CDLF on top of MSWLF.
15A NCAC 02C .0108(o) states, "Each non -water supply well shall have permanently affixed an
identification plate. The identification plate shall be constructed of a durable, waterproof, rustproof
metal or other material approved by the Department as equivalent and shall contain the following
information: (1) well contractor name and certification number; (2) date well completed; (3) total depth
of well; (4) a warning that the well is not for water supply and that the groundwater may contain
hazardous materials; (5) depth(s) to the top(s) and bottom(s) of the screen(s); and (6) the well
identification number or name assigned by the well owner." At the time of the inspection, some of the well
heads were missing identifying labels, including MW5 and MW3.
2. Many of the edge of waste markers were missing and need to be replace.
3. According to 15A NCAC 13B .1629 (c)(3), "Post -closure use of the property shall not disturb the integrity
of the cap system, base liner system, or any other components of the containment system, or the function
of the monitoring systems unless necessary comply with the requirements in this Section.
a. People riding ATVs over the landfill have left trails in the cap. It was noted during the inspection that
this is occurring during non -operating hours. Increased security measures may be necessary to prevent
unauthorized entry.
b. Trees and woody shrubs have begun to grow on landfill, which could disturb the cap. Mowing and
removal of woody growth is necessary.
6403-CDFL-2000:
The permit, issued October 24, 2018, approves the operation of Phase 4 and the continued operation of Phases 1 through
3 of the landfill. Operation of any future phases or cells (Phases 5 through 9) requires written approval of the Section
after documentation has been submitted that the area has been constructed in accordance with the approved plan, and
applicable statutes and rules.
The landfill is permitted to receive the following waste types, generated within Nash County, consistent with local
government approval: construction or demolition debris (C&D) as defined in NCGS 130A-290 (a)(4); inert debris as
defined in NCGS 130A-290 (a) (14); land -clearing debris as defined in NCGS 130A-290 (a) (15); and asphalt in
accordance with NCGS 130-294(m).
The facility accepts the following for recycling or recovery: electronic waste, waste oil, oil filters, antifreeze, cooking
oil, lead acid batteries, land clearing debris and yard waste, waste tires, white goods, pallets, scrap metal, and household
recyclables. The yard waste collection and processing area and the white goods management area are located on the
C&D landfill property. The other waste management areas are located at the entrance to the facility close to Duke Road
A responsible individual certified in landfill operations must be on -site during all operating hours of the facility
while open for public use to ensure compliance with operational requirements. The following individuals are
trained as SWANA Certified Landfill Operations Specialists:
• Emma Brantley; TS-2016014; exp: 5/24/2019
• Pamella Brinkley; LF-2008074; exp: 10/3/2020
• Sadie Tucker; LF-2015027; exp: 5/19/21
Pamella Brinkley was onsite during the inspection.
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FACILITY COMPLIANCE INSPECTION REPORT
�DK Division of Waste Management
Solid Waste Section
2. The permittee must maintain permanent markers that accurately identify the edge of the approved waste
disposal boundary. During the inspection, many of the edge of waste markers were missing.
3. The facility must actively employ a training and screening program at the facility for detecting and
preventing the disposal of unauthorized wastes, which must include random inspections of incoming loads
and records of all inspections. The facility's Operation Plan states that random load inspections will be
done and recorded at least once a week. Records for waste screening were reviewed for February 7, 2018
through December 19, 2018 and found several weeks missing. Rejected loads at the scale house were also
reviewed for February 21, 2018 through December 4, 2018. The facility must conduct weekly random load
inspections (waste screening inspections) in accordance with the Operations Plan or submit an updated Operations
Plan for approval by the Section to reflect actual practices.
4. Records of cover application were reviewed for January 5, 2018 through December 28, 2018. Weekly cover was
being applied.
5. The groundwater monitoring frequency for all detection monitoring constituents must be at least
semiannual. Records of the analytical results for groundwater quality monitoring sampling events were reviewed
and found only one sampling event for the 2018 calendar year. Please provide any other records of sampling
events for the facility that occurred in 2018.
6. Records reviewed for 2018 showed that the frequency of landfill gas well monitoring was being conducted
quarterly.
7. Electronic waste is picked up by ERI. White goods are collected by GR Mabrey Enterprises, LLC, who also
extracts the CFCs. White goods must be stored upright until freon/CFCs are removed.
8. Construction of new cells of the landfill was underway. The areas have been excavated and due to wet weather
have filled with water. The County is considering getting a syphon to remove the water. Make sure all water
is removed before disposing of waste in the new cells.
9. 15A NCAC 13B .0542 (f)(2) states, "areas which will not have additional waste placed on them for three
months or more, but where final termination of disposal operations has not occurred, must be covered
and stabilized with vegetative ground cover or other stabilizing material." The side slopes of the CDLF
were lacking vegetation and the cover had started to erode.
10. 15A NCAC 13B .0542 (g)(3) states, "At the conclusion of each operating day, all windblown material
resulting from the operation must be collected and disposed of by the owner and operator." Small
amounts of windblown material were observed around the tree -line perimeter.
11. 15A NCAC 13B .0542 (1)(2) states, "Surface water must not be impounded over or in waste." Small areas
of ponding were observed in two different places on top of the CDLF. It has been very rainy; however, the area
needs to be graded such water sheds and does not collect on top of the CDLF.
12. 15A NCAC 13B .1104 (a) states, "Landfilling of whole scrap tires is prohibited." Several tires were found
on top of the CDLF; they appeared to have been pull aside and forgotten about, but they must be removed.
a. Additionally, a couple of bicycle tires were found in the CDLF. John College and I were unsure if they
were allowable or if they were considered scrap tires. According to G.S. 130A-309.53 ""Tire" means a
continuous solid or pneumatic rubber covering that encircles the wheel of a vehicle. Bicycle tires and
other tires for vehicles propelled by human power are not subject to the provisions of this Part."
Assuming they were part of demolition waste, they are allowed in the CDLF.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Temporary Yard Waste Area:
1. Surface water shall be diverted from all operational and storage areas to prevent standing water in
operational areas and under or around storage piles. During the inspection, a small amount of water was
ponding at the base of one of the yard waste piles.
2. Non -conforming waste, such as engineered wood and plastics were observed in the YW area.
3. The location for this temporary yard waste area was approved for a one-year time frame on December
18, 2017. The one year has lapse and the County either needs to ask the Section for an extension or relocated
the waste to a new, approved area. At the time of inspection, a new yard waste area had not been designated or
decided upon. Once the location is finalized, the County must move the waste to the new area.
DS64-006:
1. This site is approved for disaster -associated yard waste and land clearing debris (vegetative waste)
ONLY. Non -conforming waste such as trash bags, plant pots, aluminum cans, tires and lumber were
observed within the disaster debris area. All non -conforming waste must be removed and disposed of in
a facility permitted to receive that type of waste.
2. Closure should be accomplished within six (6) months of initial site approval, which for this site is March
13, 2019. The site should be closed in accordance with the following guidelines. Closure is not considered
complete until the following occurs:
• All processed and unprocessed vegetative material and inert debris shall be removed to a properly approved
solid waste management site.
• Tires must be disposed of at a scrap tire collection/processing facility; white goods and other metal scrap
should be separated for recycling.
• Ash from approved air curtain burning operations shall be removed and disposed (completely cooled) at a
properly permitted municipal solid waste landfill or land applied in accordance with the Division
guidelines.
• All other materials (e.g. unrecoverable metals, insulation, wall board, plastics, roofing material, painted
wood, and other material from demolished buildings) that is not inert debris (see #1 above) as well as inert
debris that is mixed with such materials shall be removed to a properly permitted C&D recycling facility,
C&D landfill, or municipal solid waste landfill.
• Site shall be stabilized with erosion control measures, including establishment of vegetative cover, in
accordance with regulations of the Division of Land Quality.
• The Division of Waste Management shall review any temporary site to determine if the closure provisions
outlined herein have been adequately addressed.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Davy Conners
DN: cn—Davy Conners, o=Division of Waste
�1.,L': Management, ou=Solid Waste Section,
email—[e-mail], c=US
Date: 2019.02.15 13:05:25 -05'00' Phone: [phone]
Davy Conners
Environmental Senior Specialist
Regional Representative
Sent on: February 15, 2019 X Email Hand delivery US Mail Certified No. L_1
Copies: Andrew Hammonds, Eastern/Western District Supervisor - Solid Waste Section
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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Non -conform in waste ix
�"fA
wig,,
Water ponding near waste in Temporary YW Area
Water in new CDLF cells
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White good with CFCs stored on
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
CDLF side slopes lackine veLyetation and need cover.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Small amount of windblown waste.
NO
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ATV trail on closed MSWLF
Woody growth on closed MSWLF
Well head without proper label.
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