6403_INSP_20190416

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: April 16, 2019
FACILITY NAME AND ADDRESS:
Nash County C&D Landfill
SR 1425
3057 Duke Rd.
Nashville, NC 27856
Date of Last Inspection: April 2, 2019
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: solid.waste(a nashcountync.gov; Matthew.Richardson(agnashcountync.gov
FACILITY CONTACT ADDRESS:
Nash County Solid Waste
P.O. Box 849
Nashville, NC 27856
PARTICIPANTS:
Davy Conners, NC DEQ
Andrew Hammonds, NC DEQ
Donna Wilson, NC DEQ
Ben Barnes, Nash County
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:
Follow-up Compliance Inspection
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
STATUS OF PAST NOTED VIOLATIONS:
UNRESOLVED: 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 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, which is likely the cause of the leachate seep. During the April 16, 2019 follow-up inspection, the seep
was still flowing. The Count had blocked the pipe and therefore the leachate was ponding on the landfill. The County has
regraded the area and applied sod, however this has not stopped the seep from flowing. Another leachate seep was identified
on the north slope of the landfill. This seep seemed to be slowly flowing into a drainage pipe however we were unable to
definitivelv identifv the outfall of that pine. This seen is located below another berm that has impounded water.
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FACILITY COMPLIANCE INSPECTION REPORT
6 Division of Waste Management
Solid Waste Section
Leachate seep on north slope of landfill.
UNRESOLVED: 1 SA 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 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, several areas of the closed MSW
landfill were observed with water ponding over waste. These areas located along the north slope near the top, along the
northeast slope near the top, and along the southwestern slope about half way down, also had the type of vegetation that
indicates standing water is frequently an issue. During the April 16, 2019 follow-up inspection, these areas had not been
repaired. Impounding water is likely the cause of the leachate releases and seeps on the landfill. In addition, the top of
the landfill has some areas that have subsided and need to be repaired to shed water. Corrective measures need to be
underway.
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FACILITY COMPLIANCE INSPECTION REPORT
6 Division of Waste Management
Solid Waste Section
To avoid further enforcement action, within 30 days of this report the County must address the
impounded water and take measures to prevent leachate from leaving the landfill.
OBSERVED VIOLATIONS:
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, GP8 and MW6.
2. Many of the edge of waste markers were missing and need to be replace. Ben Barnes said the markers have
been ordered and will be installed when they arrive.
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
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FACILITY COMPLIANCE INSPECTION REPORT
6 Division of Waste Management
Solid Waste Section
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. Additionally, the County has been driving heavy machinery over a portion of the
closed landfill to access the temporary yard waste area, causing damage to the cap. This damage needs
to be repaired.
b. Trees and woody shrubs are growing on landfill, which could disturb the cap. Mowing and removal of
woody growth must be completed right away so that the entire landfill is accessible to Section
staff.
6403-CDFL-2000:
Burned yard waste from the old yard waste area had been piled, compacted and buried across the service
road from the new CDLF cells. This area has not been approved for disposal, there for the material must be
removed and disposed of properly, either in a LCID landfill or a CDLF that is permitted to take yard waste.
The County must submit a plan to address this area to the Section within 30 days of this report.
Burned/old yard waste.
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. Ben Barnes said
the markers have been ordered and will be installed when they arrive.
3. 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." And 15A NCAC 13B .0542
(k)(3) "Provision for a vegetative ground cover sufficient to restrain erosion must be accomplished as
directed by appropriate state or local agency upon completion of any phase of C&DLF development
consistent with Rule .0543 (c)(5) of this Section." On the CDLF cell that is no longer receiving waste there
was exposed waste and no vegetation. As a result, there were several erosion rills along the side slopes. The
CDLF needs additional cover and vegetation needs to be established.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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Lacking soil cover and vegetation on older CDLF cell and resulting erosion rills.
4. 15A NCAC 13B .0542 (1)(2) "Surface water must not impound over or in waste." The terracing on the old
CDLF cell is holding water. The area should be regraded to shed water and side slopes should be maintained in
accordance to approved drawings and plans.
Water impounding along terraces.
5. 15A NCAC 13B .0542 (k)(1 and 2) "Adequate sediment control measures consisting of vegetative cover,
materials, structures or devices must be utilized to prevent sediment from leaving the C&DLF facility...
(and) prevent excessive on -site erosion of the C&DLF facility or unit." The sedimentation basin behind the
old CDLF cell needs to be cleaned out to prevent sediment from leaving the site. In addition, measures need to
be taken to control sediment and prevent erosion.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Sedimentation pond.
At the time of the inspection, a berm around the new CDLF cell had been cut to allow surface water to
drain to the sediment basin.
a. Any changes to the design or construction of the CDLF must be approved by the Section. This
change has not been approved by the Section. The County must submit a revised plan to the Permitting
Section for approval.
b. 15A NCAC 13B .0542 (1)(4) "Leachate must be contained onsite or treated prior to discharge." If
the working face is open during a rain event, water that comes in contact with that waste (leachate) could
leave the site via this drainage area. Currently the County is covering daily or whenever a rain event
occurs. Either continue doine this or repair the area so that leachate is captured onsite.
7
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Cut in berm to allow surface water to drain could also allow leachate to leave the site.
Temporary Yard Waste Area:
1. Non -conforming waste, such as engineered wood, treated wood, plastics, and tires were observed in the
YW area.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Non -conforming waste in yard waste area.
2. The temporary yard waste storage area was approved for a one-year time frame on November 16, 2017
(see Laserfiche link for more information). The one-year time frame has lapse. The County must to submit
a plan to address the yard waste area to the Section, within 30 days of this report.
3
Surface water must be controlled to prevent water from ponding around or within waste. Waste must not
be placed in standing water. During the inspection, water was observed ponding in and near the yard waste.
As a result, black organic leachate was flowing from several places in the yard waste area into the drainage
ditch adjacent to the closed landfill. The area needs to be regraded to allow positive drainage of surface water.
Ponding water in yard waste area
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FACILITY COMPLIANCE INSPECTION REPORT
6 Division of Waste Management
Solid Waste Section
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41
Black organic leachate flowing from yard waste and into drainage ditch.
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.
At the time of inspection, the disaster debris waste and non -conforming waste had been compacted and
buried. This area is not approved for disposal. All waste, including the waste pushed towards the back -
northwest corner of the area, must be removed. Due to the wet nature of the location, the County should
consider finding a different staging area for disaster debris.
Waste pushed back in the northwest corner of site. Compacted waste in disaster debris area.
3. Closure should be accomplished within six (6) months of initial site approval, which for this site was
March 13, 2019. Please provide requested information to be granted an extension for this site.
1. What date did the County start placing waste from Florence on the site?
2. What volume of Florence debris was brought to this site in total?
3. How much Florence waste is still remaining on site now, and is it all vegetative?
4. What did the County do with the Florence waste that is no longer on site? Was it chipped, hauled, burned?
5. Where has all the waste or mulch/chipped wood been taken, and what is the plan for the rest of it?
6. What is the County's plan to have the rest of it gone by the requested extension date?
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FACILITY COMPLIANCE INSPECTION REPORT
6 Division of Waste Management
Solid Waste Section
4. 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.
Within 30 days of receiving this report, the County must submit a plan to the Section detailing actions
and time frames to address the Observed Violations.
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.
ADDITIONAL COMMENTS
Please follow up with the Permitting Branch with regards to questions about notified and permitted LCIDs. Any
changes to your operations need to be submitted to Permitting prior to enacting those changes.
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
Management, ou=Solid Waste Section,
email=[e-mail], c=US
Date: 2019.04.1809:28:53-04'00' Phone: [phone]
Davy Conners
Environmental Senior Specialist
Regional Representative
Sent on: April 18, 2019 X Email Hand delivery US Mail Certified No. L_J
Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section
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