7602_INSP_20190328

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Randolph
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 76-02
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill X DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: March 28, 2019 Date of Last Inspection: June 26, 2018
FACILITY NAME AND ADDRESS: Energizer Manufacturing, Inc. Industrial Scrap Battery Landfill County Land Road Randleman, NC 27317 GPS COORDINATES:
N: 35.75136 W: -79.76899 FACILITY CONTACT NAME AND PHONE NUMBER:
Julia Bowman, Engineering Specialist SHEA w. 336-672-4546 c. 336-736-2022
[e-mail] FACILITY CONTACT ADDRESS:
Energizer Holdings, Inc.
Julia Bowman, Engineering Specialist SHEA
419 Art Bryan Drive Asheboro, NC 27203

PARTICIPANTS:
Chuck Kirchner, Environmental Senior Specialist - Solid Waste Section (SWS)
Julia Bowman, Engineering Specialist SHEA – Energizer Holdings, Inc.
STATUS OF PERMIT:
Permit To Operate (PTO) issued November 6, 2017 Permit Approval is for Life-of-Site PURPOSE OF SITE VISIT: Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS:
None
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 3
ADDITIONAL COMMENTS
On March 28, 2019, Chuck Kirchner, met with Julia Bowman to conduct a comprehensive inspection of the Energizer Manufacturing, Inc. Industrial Scrap Battery Landfill on County Land Road in Randleman, Randolph County.

1. The industrial landfill is located on property owned by Energizer Battery Manufacturing, Inc. 2. Access to the landfill is via the Randolph County Solid Waste Facility located at 1254 County Land Road (follow gravel road past [inactive] transfer station 76-03, take first right). 3. The facility permit, site plan, and operations plan were discussed. 4. The landfill is not currently in operation. Ms. Bowman stated that scrap batteries have not been placed in the landfill since ~ 2010.
5. Ms. Bowman stated that Energizer Manufacturing, Inc. would like to maintain the active facility permit. 6. The facility is permitted to accept scrap batteries from the battery manufacturing operation located at the Energizer Manufacturing, Inc. plant (Plant # 2) in Asheboro, North Carolina. 7. The industrial landfill consists of Phases 1, 2, and 3A. Phase 1 is closed, Phase 2 contains intermediate cover, and Phase 3A has been constructed. 8. Phase 3A is atop Phase 1. It has not been used to date. Ms. Bowman stated that waste that did go to the landfill
is currently being sent to Ameristeel in Charlotte for recycling. 9. In the future, Phases 3A, 3B, and 3C will extend atop Phases 1 and 2. 10. The landfill is expected to be composed of 11 phases [Phases 1, 2, 4, and 5 are/will be horizontal and Phases 3A, 3B, 3C, and 4 through 9 are/will be vertical/above Phases 1 through 5]. 11. Phases 1 and 2 are clay-lined and Phase 3A contains a synthetic liner. A 60-mil HDPE temporary berm flap has been installed along the northern perimeter of Phase 3A (future Phase 3B tie-in). 12. Future landfill phases will use a synthetic liner. 13. Phases 1, 2, and 3A each have a leachate line clean-out access pipe(s).
14. Ms. Bowman stated that if the landfill were to operate it would be contracted to a third-party to manage. 15. The facility annual report (FAR) dated July 9, 2018 was received by the SWS. Facility throughput for July 2017 through June 2018 is 0.00 tons.
16. The facility is permitted to use a tarp as alternative daily cover. 17. The facility has three groundwater monitoring wells: MW-1A, MW-2A, and MW-3A. 18. The facility maintains semiannual groundwater monitoring records prepared by Pyramid Environmental &
Engineering, PC., analyzed by ESC Lab Sciences. Records for groundwater monitoring conducted on August 7, 2018 was observed. The February report for 2019 is complete but has not been published to date.
19. The facility has a stormwater National Pollutant Discharge Elimination System (NPDES) permit, General Permit No. NCG120000. The NPDES permit became effective on November 1, 2018 and expires May 31, 2021.
20. Leachate from Phases 1 and 2 is piped to two underground storage tanks/manholes. 21. The leachate from Phase 1 collects in storage manhole number 1 and leachate from Phase 2 collects in storage manhole number 2.
22. Ms. Bowman stated that each storage manhole is ~ 3,500 gallons. 23. Two smaller tanks have been installed at the NW corner of landfill to collect the leachate from Phase 3A. The tanks currently collect stormwater which is then piped to discharge. When Phase 3A is operational the discharge
pipe will be capped. 24. Leachate manholes 1 and 2 are routinely pumped-out usually on an alternating weekly basis.

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 3
25. The two frac tanks were removed from site. Frac tanks were rented and leachate can be collected from the manholes. Frac tanks were removed as a cost saving measure and Ms. Bowman stated that, even in the heavy rainfall we have had this past season, the manholes have never reached near capacity. Manholes are pumped-out by Shamrock Environmental Corporation and the leachate is hauled to the Shamrock Environmental Corporation’s treatment facility in Guilford County.
26. The facility maintains a leachate manhole pump log. The pump log includes: manhole inspection date, manhole leachate levels, manhole pump date, and volume pumped-out for removal. Records were observed for June 26, 2018 through March 27, 2019.
27. The leachate manholes are checked by facility personnel. The manholes are not checked daily because the landfill is not in operation. 28. Leachate is tested semiannually prior to being hauled-off site. Leachate is tested concurrently with groundwater
sampling. 29. The facility maintains semiannual leachate testing records prepared by Pyramid Environmental & Engineering, PC., analyzed by ESC Lab Sciences. Records for leachate testing conducted in August 2018 was observed.
Report done on March 1, 2019 has not been submitted to date. Report is expected to go out next week per Ms. Bowman. 30. The landfill cap appeared maintained. 31. No erosion of runoff was observed. Repair eroded rills and stabilize bare areas as discussed at the landfill. 32. Edge of waste markers (signs) are in place around the landfill. 33. No active solid waste management training certifications are maintained by staff. Upon resuming landfill operations, a certified landfill operator must be on site during all hours of operation. 34. The City of Asheboro Fire Department can be contacted to respond to an emergency. 35. The facility is secured by a locked gate.
36. Access roads are of all-weather construction. 37. The facility has proper signage. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] _ Chuck Kirchner
Environmental Senior Specialist Regional Representative
Sent on: April 03, 2019 X Email Hand delivery US Mail Certified No. [ _]
Copies: Deb Aja, Western District Supervisor - Solid Waste Section
Ervin Lane, Compliance Hydrogeologist – SWS Steve Hall, Facility Manager Asheboro Facilities – Energizer Holdings, Inc. (w. 336-672-4501, [e-mail])
Julia Bowman, Engineering Specialist SHEA – Energizer Holdings, Inc. (w. 336-372-4546, [e-mail])