2601-MSWLF-1997_INSP_20200611

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: Cumberland
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 2601-MSWLF-1997
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: June 11, 2020 Date of Last Inspection: March 23, 2018
FACILITY NAME AND ADDRESS: Cumberland County (Ann Street) Landfill 698 Ann Street Fayetteville, North Carolina GPS COORDINATES: N: 35.06444° W: -78.87106° FACILITY CONTACT NAME AND PHONE NUMBER: Amanda Bader Solid Waste Director O. 910-321-6920
Email: [e-mail] FACILITY CONTACT ADDRESS: Engineering and Infrastructure Department
130 Gillespie Street, Room 214
Fayetteville, NC 28301

PARTICIPANTS: David Powell, NC DEQ, Solid Waste Section Drew Hammonds, NC DEQ, Solid Waste Section
Amanda Bader, Cumberland County Solid Waste Director Chad McClean, Cumberland County, Landfill Manager
STATUS OF PERMIT:
Permit to Construct - Phase IV (Cell 10) and Permit to Operate for Phases 1 through IV Cell 9 (Life-Of-Sit Permit) – March 22, 2018. In accordance with 130A-294 (a2) this permit is for the life-of-site. Life-of-site ends when the facility reaches its final permitted elevations or by December 17, 2057. PURPOSE OF SITE VISIT: Follow -Up Partial Inspection STATUS OF PAST NOTED VIOLATIONS: NA
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .1626 (2) - (a) Except as provided in Sub-Item (b) of this Item, the owners or operators of all MSWLF units must cover disposed solid waste with six inches of earthen material at the end of each operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing litter, and scavenging. (b) Alternative materials of an alternative thickness (other than at least six inches of earthen material) may be approved by the Division if the owner or operator demonstrates that the alternative material and thickness control disease vectors, fires, odors, blowing litter, and scavenging without presenting a threat to human health and the environment, in accordance with 40 CFR Part
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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258.21. A MSWLF owner or operator may apply for a generic approval of an alternative cover material, which would extend to all MSWLF units. (c) Areas which will not have additional wastes placed on them for 12 months or more, but where final termination of disposal operations has not occurred, shall be covered with a minimum of one foot of intermediate cover.
Cell 8 on top and side slopes had exposed waste. Intermediate cover is needed and vegetation re-established in repaired or disturbed areas. Shamrock Environmental had recently, graded, covered and seeded. Cell 9 and 10 also needed better cover. Some soil was being added with 3 additional contracted trucks to assist speeding up the process. Moving forward, be sure and cover enough, this helps prevent fires in old covered cells by controlling oxygen supply and separating “fuel” for the fire if one begins.
2. 15A NCAC 13B .1626 (8) – (a) Surface water shall be diverted from the operational area. (b) Surface water shall not be impounded over or in waste.

Impounded water was observed in disturbed and unrepaired areas on top of Cell 8 and Cells 9 and 10. These areas should be repaired and properly graded to allow for positive drainage of surface water.
ADDITIONAL COMMENTS
1. Drew Hammonds and David Powell following up on recent fire on June 3, 2020 and introduce new Solid Waste Inspector to Cumberland County and to do partial inspection.

2. Entrance had good signage out front. Roads were of all-weather construction.

3. Cell 8 needs better cover on top and sides to cover exposed waste. County staff indicated it was recently
covered, sloped and seeded by Shamrock Environmental. Ruts were visible on top. This can hold water during rainfall. Top should be graded and sloped to allow the shed of rainfall but in a controlled manner as to not become counterproductive to operations or over power the water control structures in place. Some exposed
waste item on top that are larger, such as the mattress, should be taken to working face.

4. Windblown waste must be collected and returned to the working face by the close of business each day. View of CDLF from Cell 8, one person was picking up windblown.
5. Currently work is being done in both cell 9 and cell 10. Several areas of exposed waste observed during this inspection. A tarp is onsite for covering at the working face. Will use posi-shell when tarp isn’t enough and cover once a week with soil. Also has soil/mulch mixture stockpiled nearby for cover.

6. MSWLF units shall restrict solid waste into the smallest area feasible and compacted as densely as practical into
cells. The working face extended across cells 9 and 10 at the time of the fire. Fire burned a large area from cell 9 and across cell 10 to the edge of waste on the north side of the MSWLF.

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

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7. Cumberland County staff are stripping away intermediate cover as they work across the cells to allow for waste to waste contact. Stripping away large areas of the intermediate cover and berming up for later cover does not
allow water to be diverted from the operational area.

8. Water was observed ponding in several on the intermediate cover of cells 9 and 10. Be sure to grade areas properly and repair any disturbed areas to allow for positive drainage of water from over the waste.
9. All waste must be covered at the end of the working day. Facility staff discussed the possibility of street
sweepings being used as ADC or covering with posi-shell. Further discussion required on the use of street sweepings as ADC.

10. Western slope of Cell 9 has a seep beside road. It’s near the road ditch so it needs addressing quickly.

11. Southeastern side slope, along middle way, another eroded area needs repair.

15A NCAC 13B .1626 (7) (a) - Adequate sediment control measures (structures or devices), shall be utilized to prevent silt from leaving the MSWLF facility.

12. Cell 10 should have a 4 foot offset from the edge of liner to the perimeter ditch. The waste was observed
pushed up to the edge and in some places beyond the liner and up to the ditch. This can defeat the purpose of the liner containing the leachate from the waste and make it difficult to cover correctly. It also is counterproductive to the foundation of proper slope construction as the height of waste increases. Waste should
be pushed back away from edge into the liner footprint, carefully not to disturb the liner, sloped and covered correctly. This will also allow room for any remedial action in future with liner issues, seeps etc.

13. Leachate collection system is discharged daily ~ 20,000 gpd to PWC Cross Creek WWTP.

14. Solid Waste staff discussed corrective actions and maintain facility in compliance goals. County staff mentioned staffing issues, recently hired 3 additional trucks to assist with catching up on covering properly in
Cell 9 and 10. Additional short term contracting was discussed to help fix and maintain issues onsite.

15. A more in depth inspection will be conducted in the future. Heavy rainfall during this inspection caused it to be cut short.
16. Corrective measures are necessary and should be completed within 30 days’ receipt of this inspection report.

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Cell 9 to the left and cell 10 to the right. Looking from side of cell 8.
Ruts and exposed waste on top cell 8. Grade properly, cover and remove big items to working face to cover. Be sure and establish vegetation to reduce erosion.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Waste being pushed to edge of liner next to ditch and covered. Be sure waste has permitted separation from edge of liner.

Eroded areas need soil and vegetation. Possible further water control structures are needed to slow storm water down so that it erodes so aggressively. Otherwise just replacing the soil will not stop underlying issue and the next big rainfall same problem occurs again.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: 910 – 433 – 3350 _ David Powell Environmental Senior Specialist Regional Representative
Sent on: June 29, 2020 Email Hand delivery US Mail Certified No. [ _]

Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Ben Jackson, Permitting Branch Engineer Amanda Freeman, Compliance Officer Amanda Bader, Cumberland County Solid Waste Director Chad McClean, Cumberland County Landfill Manager