6401_INSP_20191121&20200211

NORTH CARnLINAD_E Q�/��
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
CIDIT
X
Tire T&P/
X
Tire
Industrial
DEMO
SDTF
Collection
Monofrll
Landfill
Date of Site Inspection: February 11, 2020 and November 21, 2019
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 °
Date of Last Inspection: April 16, 2019
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Ben Barnes and Matthew Richardson
Telephone: [phone] (Barnes cell 252-904-3396)
Email address: solidwaste(cr�,nashcountync.gov; Matthew.Richardson(cr�,nashcountync.gov
FACILITY CONTACT ADDRESS:
Nash County Solid Waste
P.O. Box 849
Nashville, NC 27856
PARTICIPANTS:
Davy Conners, NC DEQ
Andrew Hammonds, NC DEQ
Matthew Richardson, Nash County
Craig Fortner, Garrett & Moore, Inc. (February 11, 2020 only)
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 (640 1 -MSWLF- 19 83), construction and
demolition waste 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.
Temporary Yard Waste Area approval was issued November 16, 2017 and expired on November 16, 2018.
DS64-006: Activated September 13, 2018, must be deactivated by March 13, 2019.
PURPOSE OF SITE VISIT:
Follow-up Compliance Inspection
Page 1 of 11

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
STATUS OF VIOLATIONS IN THE MARCH 12, 2019 NOTICE OF VIOLATION LETTER AND APRIL 18,
2019 NOTICE OF CONTINUING VIOLATION LETTER:
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 NCAC13B .1626 (8)(d), "Leachate shall be contained within a lined disposal cell or leachate collection and
storage system. "
Nash County remains in violation of the above rules in that leachate was observed on November 21, 2019, seeping
from the same location as during the January 23, 2019 and April 2 and 16, 2019 inspections. (Figure 1). During the February
11, 2020 inspection, the area of this leachate seep had been regraded and repaired. The area was wetter than the surrounding
area and was flowing, however because of rain that day, I could not confirm that it was leachate not surface water (Figure
2). In April of 2019 a similar repair to the area was made, however leachate continued to seep from this location. Above
the seep was an area of impounded water, observed during the February 11, 2020, April 16, 2019 and January 23, 2019
inspections, which is likely the cause of the leachate seep and will likely continue to cause a seep until it is repaired.
1='Sirs (• �' `". v . hssa 9 ��.� ty �', � t i�"K.
•� I
e i6 day
u,allk
tee.
Figure 1: November 21, 2019: Leachate seep at northeast corner of landfill.
Figure 2: February 11, 2020: Area of leachate seep on northeast corner of landfill with repairs.
Page 2 of 11

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
DP8 to E°°'�m"" lW,Ift Solid Waste Section
STATUS OF OBSERVED VIOLATIONS NOTED IN JANUARY 23, APRIL 2, AND APRIL 16, 2019
INSPECTION REPORTS:
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: (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 remains in violation of the above rules in that, during the November 21, 2019 inspection, several
areas of the closed MSW landfill were observed with water ponding over waste. The County had installed weep drains
along the berms, however some of these areas with weep drains had water ponding near and on top of the drains.
Impounding water is likely the cause of leachate releases and seeps on the landfill. In addition, the north slope of the
landfill has some areas that have subsided and need to be repaired to shed water (Figures 3-5). During the February 11,
2020 inspection, water was observed in several of the weep drain areas and in the berm area at the northeast corner of the
landfill which does not have a weep drain (Figure 6).
Figure 3 and 4: November 21, 2019: Impounded water over waste.
Figure 5: November 21, 2019: Bowl -shaped subsidence on the north slope.
Page 3 of 11

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"—t0E-!�'m""lW'Ift Solid Waste Section
Figure 6: February 11, 2020: Impounded water over waste.
STATUS OF OBSERVED VIOLATIONS NOTED IN APRIL 16, 2019 INSPECTION REPORT:
UNRESOLVED: 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. UNRESOLVED: People riding ATVs over the landfill have left trails in the cap. The County has put
up no trespassing signs, however during the February 11, 2020 inspection, evidence of recent ATV
activity was observed. Increased security measures are necessary to prevent unauthorized entry.
b. UNRESLOVED: Trees and woody shrubs are growing on landfill, which could disturb the cap. As of
the February 11, 2020 inspection, mowing and removal of some woody growth had been completed,
however there are some areas that still need to be cleared (Figure 7).
Figure 7: February 11, 2020: ATV trails and trees on landfill.
2. UNRESOLVED, PROGRESS UNDERWAY: Burned yard waste from the old yard waste area had been
piled, compacted and buried across the service road from Phase 4 of the CDLF (Cells 4A and 4B). This
area is not approved for disposal. The Section approved a plan and extension of the deadline for compliance for
July 31, 2019 for "the materials in this stockpile that are substantially free of stumps and/or identifiable wood
waste to be used in the planned stabilization of the inactive portions of the operating CDLF. All stumps and
land clearing materials larger than can be used for this application, must be treated as yard waste in accordance
with Nash County Landfill's Operation Plan, which states that yard waste will be ground, and Nash County
Landfill's Permit to Operate which states, `at least 75% by weight of recyclable and recovery material must be
removed from the site within one year."' As of the February 11, 2020 inspection, some of this material had
been removed to be used on Cell 4A, however the majority of it remained (Figure 8). On March 2, 2020, the
County sent an email showing work being done on the closed CDLF, including using the burned yard waste for
a vegetative stabilization layer.
Page 4 of 11

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Figure 8: November 21, 2019: Burned yard waste pile.
3. UNRESOLVED, PROGRESS UNDERWAY: 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." The
old CDLF (Phases 1-3) has not been used since at least April 2, 2019 and has not been properly covered and
stabilized. Erosion rills and large amounts of exposed waste were observed on the side slopes during both the
November 21, 2019 and February 11, 2020 inspections (Figure 9). The County provided the Section with a
copy of a contract between the County and S.A.C. Enterprises Inc., dated October 31, 2019, for the repair work
on the CDLF, but as of the February inspection, this work had not been started. On March 2, 2020, the County
sent an email showing work being done on the closed CDLF.
Figure 9: February 11, 2020: Old CDLF cell with insufficient cover, no vegetation, and exposed waste.
4. UNRESOLVED: 15A NCAC 13B .0542 (1)(2) "Surface water must not impound over or in waste." The
terracing on the old CDLF (Phase 1-3) was still holding water during the November 21, 2020 inspection (Figure
10). The CDLF was too wet to inspect during the February 11, 2020 inspection, however County staff said the
repair work had not been started yet. This is part of the work that has been contracted out to S.A.C. Enterprises
Inc. as reference above.
Page 5 of 11

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Figure 10: Water impounding over waste and exposed waste on old CDLF cell.
5. UNRESOLVED: 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." According to
County staff, two of the three sedimentation basins have been cleaned out, however Section staff was unable to
verify due to wet, muddy conditions during the February 11, 2020 inspection. The new sediment basin still
needed to be cleared out to prevent sediment from leaving the site (Figure 12 and 13). Additionally, measures
such as vegetative cover, materials, etc. still needed to be utilized to prevent onsite erosion and sediment from
leaving the facility.
Figure 12: November 21, 2019: Sediment basin for Phase 4 CDLF.
Figure 13: February 11, 2020: Sediment basin for Phase 4 CDLF.
6. UNRESOLVED: Non -conforming waste, such as treated wood and plastics were observed in the
Temporary Yard Waste area. According to Mr. Richardson during the November 21, 2019, the non-
conforming waste is removed weekly and place in a dumpster. Waste screening and removal should be done
daily. During the February 11, 2020 inspection, non -conforming waste was still present in the yard waste area.
The County had installed signs saying, "No trash/paper in yard waste."
7. UNRESOLVED: 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 lapsed on
November 17, 2018. Yard waste was still being stored in this area during the February 11, 2020 inspection. All
yard waste in this area needs to be either:
a. Ground in accordance with the Nash County Landfill's Operation Plan, or
Page 6 of 11

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"' t0E­!�'m"""°"""' Solid Waste Section
b. Disposed of in the Nash County CDLF, which is permitted to accept land clearing waste. If the County
chooses to dispose of yard waste in this manner, it must first remove any municipal solid waste type
material that might be comingled.
After removing the material from this area, regrade, establish vegetation and discontinue use as storage of yard
waste.
The County has submitted a permit application for a Land Clearing and Inert Debris (LCID) Landfill.
However, as stated in the February 11, 2020 meeting, the County cannot choose to not comply with the law
while a permit is under review. The waste in this area has been stockpiled for over a year if not longer and the
County has known for over 18 months that a permit was needed. The permit application itself was not
submitted until well after the temporary approval expired. Further the Section has offered at least two
alternative short-term management methods to remove the waste until a permit can be secured.
8. UNRESOLVED: Surface water must be controlled to prevent water from ponding around or within
waste. Waste must not be placed in standing water. During the February 11, 2020 inspection, water was still
observed ponding in and near the temporary yard waste area and there was black organic leachate flowing from
the yard waste piles (Figure 14).
Figure 14: February 11, 2020: Ponding water and black leachate in temporary yard waste area.
Additionally, during the November 21, 2019 and February 11, 2020 inspections, water was observed ponding
around the temporary disaster debris yard waste area (DS64-006). That water was black with organic leachate
(Figure 15). Due to the wet nature of the location, the County should consider finding a different staging area
for disaster debris.
Figure 15: November 21, 2019: Ponding water in disaster debris yard waste area.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"' t0E­!�'m"" lW'Ift Solid Waste Section
9. UNRESOLVED: The Temporary Disaster Debris site (DS64-006) was approved for disaster -associated
yard waste and land clearing debris (vegetative waste) ONLY. During the January 23, 2019 inspection,
non -conforming waste such as trash bags, plant pots, aluminum cans, tires and lumber were observed within the
disaster debris area. As of the February 11, 2020 inspection, this non -conforming waste had not been removed
(see next violation). All non -conforming waste must be removed and disposed of in a facility permitted to
receive that type of waste. If the county chooses to dispose of this material in the CDLF (which is permitted to
receive land clearing waste), it must first remove any municipal solid waste type material that might be
comingled.
10. UNRESOLVED: At the time of the April 16, 2019 inspection, the disaster debris waste and non-
conforming waste had been compacted and buried. During the February 11, 2020 inspection, the area had
not been removed of waste and was starting to grow grass and weeds over the waste (Figure 15). This area is
not approved for disposal. All waste, including the waste pushed towards the back -northwest corner of the area,
must be removed.
11. UNRESOLVED: Closure should be accomplished within six (6) months of initial site approval, which for
this site was March 13, 2019. In the April 2, 2019 Inspection Report, the Section requested information to
grant the County with an extension, however the information was not provided to the Section and closure of the
site has not been completed.
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.
12. RESOLVED: 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." Well
heads have been labeled with identification tags (Figure 16).
Page 8 of 11

NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Figure 16: November 21, 2019: Well head ID tag.
13. RESOLVED: Many of the edge of waste markers were missing on the closed MSWLF but have since been
replaced.
14. RESOLVED: At the time of the April 16, 2019 inspection, a berm around CDLF Cell 4A had been cut to allow
surface water to drain to the sediment basin. During the November 21, 2019 inspection, the berm from Cell A
had been repaired and the cell was not in use, however the berm from Cell 4B had been cut into to allow surface
water to drain into the sediment basin. During the February 1, 2020 inspection, the berm had been repaired.
a. RESOLVED: Any changes to the design or construction of the CDLF must be approved by the
Section.
b. RESOLVED: 15A NCAC 13B .0542 (1)(4) "Leachate must be contained onsite or treated prior to
discharge."
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
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 was violation of the above rules in that leachate was observed on November 21, 2019, flowing
near the base of the north slope of the landfill, passed the edge of waste, and into a drainage ditch between the
Page 9 of 11

FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"—t0E-!�'m"""°"""' Solid Waste Section
landfill and the temporary vegetative waste area (Figure 17). During the February 11, 2020 inspection, this area
had been plugged with soil however there was a liquid flowing next to the plug (Figure 18). Due to rain that
day, I could not confirm if this was leachate or surface water. I will revisit this location during the next
inspection. In the meantime, the County should inspect this area frequently to make sure a leachate
outbreak does not recur.
Figure IT November 21, 2019: Leachate release on north slope of landfill.
Figure 18: February 11, 2020: Area has been plugged but remains wet.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
OepaNnent of Envieonmenlel Welily
Solid Waste Section
• During the November 21, 2019 inspection, use of Cell 4A had been halted for the past 3 to 4 weeks, and the
County was using Cell 4B. At that time, adequate cover and stabilizing material has not been added to Cell 4A
(Figure 19). When we re -inspected in February 11, 2020, this cell had been covered with soil and the burned
yard waste material and had been seeded and strawed. Good job.
Figure 19: February 11, 2020: Cell 4A.
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, (� [� �7 �7 p (�
email=020.0conners 9:23-0 '00' c=US Phone: (919) / 0 / —8290
Date: 2020.03.04 15:59:23-OS'00'
Davy Conners
Environmental Senior Specialist
Regional Representative
Sent on: March 4, 2020 X Email Hand delivery US Mail Certified No.1 ]
Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section
Page 11 of 11