6401_NOCV_County_RESP_20190416

BOARD OF
COMMISSIONERS
ROBBIE B. DAVIS
CHAIRMAN
FRED BELFIELD, JR.
DAN CONE
SUE LEGGETT
J. WAYNE OUTLAW
LOU M. RICHARDSON
MARY P. WELLS
May 17, 2019
Mr. Davy Conners
Environmental Senior Specialist
NCDEQ —Waste Management
1646 Mail Service Center
Raleigh, NC 27599-1646
Nash County
Re: Notice of Continuing Violation, Nash County Landfill, 6401-MSWLF-1983
Dear Mr. Conners,
ZEE B. LAMB
COUNTY MANAGER
ZEE. [e-mail]
VINCE DURHAM
ATTORNEY
[e-mail]
JANICE EVANS
CLERK TO BOARD
JANICE. [e-mail]
Nash County has reviewed the subject Notice of Continuing Violations and is committed to addressing the issues
raised by NCDEQ. In that regard, we have requested guidance from our consulting engineers, Garrett & Moore,
Inc. Garrett & Moore's staff have assisted with Nash County's solid waste program since the mid-1990's, and
have a full understanding of Nash County's programs, capabilities, and commitment to working in cooperation
with NCDEQ staff.
Nash County intends to follow the recommendations and time frames set forth in the attached letter from Mr.
Vance F. Moore, PE, of Garrett & Moore, subject to approval of the Nash County Board of Commissioners.
The contents of this letter and attachments will be shared with the Board of Commissioners on May 20, 2019,
at which time we expect Nash County will proceed immediately with the recommended actions. If the Board of
Commissioners directs a different approach and/or time frames, we will communicate immediately with
NCDEQ staff and revise the plan accordingly.
Sincerely,
Zee Lamb
Nash County Manager
CC: Ed Mussler, Solid Waste Section Chief
Carolyn McClain, Assistant Attorney General
Jason Watkins, Field Operations Branch Head
Andrew Hammonds, Eastern District Supervisor
Jessica Montie, Compliance Officer
120 WEST WASHINGTON STREET - SUITE 3072 • NASHVILLE. NORTH CAROLINA 27855
PHONE: [phone] - FAX: [phone]

GARRETT � ■
& MOORE
Engineering for the Power and Waste Industries
May 16, 2019
Mr. Zee Lamb
Nash County Manager
120 W. Washington St.
Suite 3072
Nashville, NC 27856
RE: Notice of Continuing Violation
Nash County Landfill
6401-MSWLF-1983
Actions and Time Frames to Address Observed Violations
April 16, 2019 Inspection
Mr. Lamb:
The State of North Carolina, Division of Waste Management Solid Waste Section
(Section) issued a Notice of Violation letter to Nash County Landfill regarding facility
violations dated April 18, 2019. The violations are described in the Facility Compliance
Inspection Report dated April 16, 2019 issued by the Section and received by Nash
County on April 18, 2019. Per the inspection report, Nash County must submit a plan to
the Section detailing actions and time frames to address the observed violations within
30 days of receiving the inspection report.
We have reviewed the April 16, 2019 inspection report and performed independent field
reconnaissance of the violations described. Following are our recommended actions and
time frames to address violations documented in the Section's report. Please note that
the time frames recommended allow for time to secure contracts to perform the work. We
understand that in actions where costs are anticipated to exceed $50,000, the need for
Nash County Commissioner approval is required. Timeframes proposed for these items
account for the Board of Commissioners meeting schedule.
PAST NOTED VIOLATIONS:
Overall the MSWLF cap system is in very good condition; the water management issues
noted in the inspection area due to settlement occurring since final cover construction.
We recommend remediating the problem locations with minimal disturbance to the
existing cap and its cover system components.
1. Closed MSWLF — Stormwater seeps
We believe the liquid observed at the surface of a recently graded area at the east
face of the closure landfill is likely impounded stormwater in a saturated location
seeping to the surface.
1100 Crescent Green Drive, Suite 208, Cary, North Carolina 27518 • O: 919-792-1900 • F: 866-311-7206

Mr. Zee Lamb
May 16, 2019
Page 2
We recommend adding soil in this area to reestablish a suitable grade (percent slope)
allowing the saturated areas of the vegetated cover to drain and alleviate.
2. Closed MSWLF — Impounded surface water
Upon inspection of the closed landfill, we have observed several locations with
standing water in existing terrace berm ditch lines. The impounded water within the
terrace ditches is due to settlement occurring since final cover installation, resulting in
a reduced slope toward inlets of downdrain pipes. To remedy these areas, we
recommend installing weep drains in settled areas of the terrace berm ditches; the
weep drains would consist of the following:
■ A 3-foot piece of 2" perforated PVC pipe surrounded by 6" of gravel and filter
fabric which drains through a solid %" PVC pipe through the terrace berm to the
point where it daylights on the side slope. The proposed drains are not
designed to manage stormwater from rain events. By our inspection there is no
evidence of erosion of the terrace berm and ditch due to water depth exceeding
the terrace berm ditch capacity. The proposed drains are designed to dewater the
impounded water. A typical detail of the proposed ditch drains is attached to this
InstAR1166 of weep drains and any re -grading should be monitored on -site to minimize
disturbance of the final cover system, specifically the low -permeability infiltration layer.
All areas where vegetation is disturbed should be re -seeded and stabilized.
All areas addressed on the MSWLF should be regularly inspected following the work
to ensure ditches are functional, areas with previous impounded water are relieved,
and stabilization occurs.
► July 31, 2019 — Completion of drain installation and re -grading efforts.
OBSERVED VIOLATIONS
6401-MSWLF-1983 & 6401-CDLF-1999 (CLOSED LANDFILL)
1. Non -Water Supply Well Identification Plates
Permanent identification plates should be installed on MW5, MW3, MW6, and GP8 in
compliance with state regulations.
Additionally, all monitoring wells at the facility should be inspected for compliance, well
structure integrity and security. Any observed issues should be addressed. The
inspection report as well as all repair actions should be documented and maintained
in the operating record.
► July 31, 2019 — Identification plate installation completion

Mr. Zee Lamb
May 16, 2019
Page 3
2. Edge of Waste Markers
► July 31, 2019 — Edge of waste markers should be installed and/or replaced at
minimum every 400-feet and at corners of the closed facility
3. (a) ATVs Operating on the Landfill Cap
We recommend the County inspect existing property line postings and install new "NO
TRESPASSING" postings along property lines and prominently at potential and
suspect locations of entry. The County may also consider requesting an increase in
sheriff's patrolling the facility during closed hours.
► July 31, 2019 — Install additional signage as necessary and request increase in
patrolling of the facility during closed hours.
(a) Damage to the Cap from heavy machinery
► July 31, 2019 — All damage to the cap from heavy machinery traffic should be
repaired. Other routes to access the front (northern) portion of the facility should
be initiated, and the closed landfill should not be used as a traffic route for heavy
equipment.
(b) Trees and woody shrubs growing on the closed landfill
► June 30, 2019 — Maintenance by mowing should be performed; trees and
unwanted woody growth should be removed. Woody vegetation too large to
remove by mowing should be hand -cut at ground level and removed with minimal
disturbance to cap soils.
Going forward, an inspection schedule of the closed facility should be implemented to
identify potential issues and problem areas and to address in a timely manner. A
maintenance schedule should be implemented to maintain the vegetation and more
routinely eliminate unwanted growth.
6403-CDLF-2000 (OPERATING LANDFILL)
1. Burned yard waste from the old yard waste area had been piled, compacted and
buried across the service road from the new CDLF
A substantial proportion of the material stockpiled across the service road from the
new C&DLF is decomposed, with a composition similar to a rich organic topsoil.
Materials in this stockpile that are substantially free of stumps and/or identifiable wood
waste should be used in the planned stabilization of the inactive portions of the
operating C&DLF, as described in Item 3 below.
Nash County should consider permitting a Land Clearing and Inert Debris (LCID)
Landfill in the vicinity of the current C&DLF. A figure showing a conceptual location
and layout of an LCID Landfill is included as an attachment to this letter.

Mr. Zee Lamb
May 16, 2019
Page 4
While constructing a permitted LCID Landfill is the recommended course of action, we
understand that there are a number of questions to be answered and issues that need
to be vetted before Nash County can commit to this course of action. Furthermore,
we recognize that such an action would likely require input from the County
Commissioners. To this end, we would recommend scheduling a presentation to the
County Commissioners at the next available opportunity (Monday, May 20t") to
discuss this matter in more depth. Ultimately, the goal should be determining a
preferred course of action and communicate this decision to the NCDEQ within the
next 45 days. In the event the County Commissioners are not inclined to invest in
construction of such a facility, the County will need to make other arrangements to
have this material transported to and disposed in another permitted facility in the
county.
2. Maintain permanent markers that accurately identify the edge of approved waste
disposal boundary
► July 31, 2019 — Edge of waste markers should be installed and/or replaced at
minimum every 400-foot and at corners of the closed facility
3. On the CDLF cell no longer receiving waste, exposed waste and no vegetation;
erosion rills on sideslopes observed
► July 31, 2019 — Any area with exposed waste should be soil covered as required.
Incidental uncovered waste should be placed in the active C&DLF.
► July 31, 2019 —All exposed soil covered areas which will not have additional waste
placed for three months or more, but where final termination of disposal operations
has not occurred should be seeded and mulched.
Seeded areas should be inspected regularly; bare areas should be re -seeded.
Additionally, going forward all seeding events should be logged with a record of
seeding activities maintained on site.
4. The terracing on the old CDLF is holding water
► July 31, 2019 — The CDLF should be re -graded to prevent impounding of water.
All disturbed inactive areas should be seeded.
5. The sediment basin behind the old CDLF needs to be cleaned out
► July 31, 2019 —the sediment basin should be cleaned out, removing sediment and
establishing the pond to approximate design grades. Disturbed areas should be
seeded.
6. The berm around the new CDLF cell has been cut to allow surface water to drain to
the sediment basin

Mr. Zee Lamb
May 16, 2019
Page 5
(a) Any changes to design or construction of the CDLF must be approved by the
Section
► July 31, 2019 —The berm around the new C&DLF should be reconstructed per the
approved plans. Additionally, revised plans should be submitted to the Section
that reflect the County's desired removal of the soil berm between C&DLF Cells
4A and 4B.
(b) Leachate must be contained onsite or treated prior to discharge
The revised Plan should describe landfill filling progression as to not impound
water in the active cell.
TEMPORARY YARD WASTE AREA
1. Non -conforming wastes were observed in the YW area
► July 31, 2019 — all visible non -conforming waste should be removed from the yard
waste area and hauled to the landfill for disposal (C&D wastes) or removed and
managed as appropriate.
2. The temporary yard waste storage area was approved for one-year time frame on
November 16, 2017
► As discussed previously, Nash County should consider permitting a Land Clearing
and Inert Debris (LCID) Landfill in the vicinity of the current C&DLF or make other
arrangements for final disposal of yard waste. The County should seek to provide
the Section notification of the preferred course of action regarding long-term
management of LCID waste within the next 45 days.
3. Surface water must be controlled to prevent water from ponding around or within
waste
Surface drainage of the temporary yard waste area should be improved to prevent
ponding.
► July 31, 2019 — grading of the temporary yard waste area to allow positive
drainage of surface water
DS64-006 (DISASTER -ASSOCIATED YW AREA)
1. This site is approved for disaster -associated yard waste and land clearing debris only.
► July 31, 2019 — all visible non -conforming waste should be removed from the yard
waste area.
2. The disaster debris waste and non -conforming waste had been compacted and buried
► The County should seek to provide the Section notification of the preferred course
of action regarding long-term management of LCID waste within the next 45 days.

Mr. Zee Lamb
May 16, 2019
Page 6
3. Closure should be accomplished within 6-months of initial site approval, which for this
site was March 13, 2019
► July 31, 2019 — Submit requested information required to be granted an extension.
► The County should seek to provide the Section notification of the preferred course
of action regarding long-term management of LCID waste within the next 45 days.
It is our opinion that the recommended actions and timeframes described herein
adequately address concerns raised by the Section in the April 16, 2019 Facility
Compliance Inspection Report. Please contact us if you have any questions.
Sincerely,
GARRETT & MOORE, INC.
Ince F. oore, P.E.
President
Attachments

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