HomeMy WebLinkAboutAnson Hazardous Waste Assessment Plan_04162021
January 12, 2021
Ms. Teresa Bradford Environmental Senior Specialist Division of Waste Management – Solid Waste Section 610 East Center Avenue, Suite 301
Mooresville, NC 28115
Dear Ms. Bradford: Subject: Hazardous Waste Assessment Plan
Chambers Development MSW Landfill (Anson County Landfill)
Permit Number 0403-MSWLF-2010 Anson County CEC Project 165-276
Civil & Environmental Consultants, Inc. (CEC), on behalf of Chambers Development of North
Carolina, Inc., respectfully submits this response to the Notice of Violations (NOV) received on December 15, 2020. This response includes a Hazardous Waste Assessment Plan that includes the requested information in the NOV. Specifically, this plan includes a description of the location of the waste, an assessment of the waste, the facility’s unauthorized waste control
program, and an updated leachate monitoring plan.
Should you have any questions or require any additional information in support of this application, please do not hesitate to contact me at 980-237-0373.
Sincerely,
CIVIL & ENVIRONMENTAL CONSULTANTS, INC.
Nathan Bivins, PE Scott L. Brown, PE Project Manager Vice President
Attachments
Revised April 2021
-i- Hazardous Waste Assessment Plan
January 2020
TABLE OF CONTENTS
1.0 BACKGROUND ................................................................................................................1
2.0 SITE DESCRIPTION ........................................................................................................2 2.1 Physical Setting ....................................................................................................... 2 2.2 Gypsum Waste Disposal Location .......................................................................... 2
3.0 UNAUTHORIZED WASTE CONTROL ........................................................................4
4.0 WASTE ASSESSMENT ....................................................................................................6
5.0 LEACHATE MONITORING PLAN ...............................................................................9
6.0 SUMMARY ......................................................................................................................11 FIGURES Figure 1 – Approximate Gypsum Waste Location
-1- Hazardous Waste Assessment Plan
January 2020
1.0 BACKGROUND
This Hazardous Waste Assessment Plan (HWAP) for Chambers Development MSW Landfill
(Anson County Landfill) has been prepared in response to a Notice of Violation (NOV) dated
December 15, 2020. According to the NOV, on September 21 and 22, 2020, approximately 631
tons of gypsum from the American Zinc Products, LLC facility located in Mooresboro, North
Carolina was transported for disposal to the Anson County Landfill. Landfill records show that a
total of 449.77 tons of gypsum waste material was disposed in the landfill between September
21st and 22nd of 2020. Subsequent toxicity characteristic leaching procedure (TCLP) test results
of the gypsum waste showed the sample contained cadmium concentrations of 1.1 milligrams per
liter (mg/l), which is 0.1 mg/l above the hazardous waste standard of 1.0 mg/l. As requested in
the NOV, the purpose of this HWAP is to complete the following:
• Document the location of the hazardous gypsum waste (Section 2.2);
• Identify actions to ensure that hazardous waste is not received at the facility (Section
3.0);
• Assess the potential mitigation and management options for the hazardous gypsum waste
(Section 4.0); and
• Update the leachate monitoring plan (Section 5.0).
-2- Hazardous Waste Assessment Plan
January 2020
2.0 SITE DESCRIPTION
The Anson County Landfill is situated in the south-central portion of Anson County, North
Carolina. The landfill facility is classified as a municipal solid waste (MSW) landfill and
operates under Permit Number 0403-MSWLF-2010. Development of the landfill facility is
progressing incrementally in five phases with each phase being comprised of smaller cells. The
general intent is to construct a phase incrementally within the landfill when needed. Permits to
Construct for Phase 1 and Phase 2 expansions were issued by the North Carolina Division of
Environmental Quality (NCDEQ) Solid Waste Section (SWS) in 2000 and 2008, respectively.
The footprint of Phase 1 is approximately 40.38 acres, and Phase 2 consists of 32.78 acres. Both
of these existing phases are currently operational. A Permit to Construct Application for Phases
3 and 4 was completed by Civil & Environmental Consultants, Inc. (CEC) in November 2016,
and approved by NCDEQ on March 26, 2018. Phases 3 and 4 will include a total of 60 acres,
bringing the total landfill area to 133 acres. The facility owner has recently initiated the
preliminary site suitability studies for the subject Phase 5 expansion landfill area.
2.1 PHYSICAL SETTING
The site is bounded on the northwest by Brown Creek, on the east by Pinch Gut Creek, and on
the south by a CSX rail line. The immediate surrounding area is rural and primarily wooded.
There is limited residential development south of the landfill facility. The site consists of a
series of rolling hills that reach elevations of approximately 300 feet above mean sea level and
low-lying areas adjacent to Brown and Pinch Gut Creeks at an elevation low of approximately
240 feet above mean sea level. Generally, surface drainage from the landfill facility is to the
northwest toward Brown Creek and northeast toward an unnamed tributary of Pinch Gut Creek.
2.2 GYPSUM WASTE DISPOSAL LOCATION
Approximately 450 tons of gypsum waste from the American Zinc Products, LLC facility
located in Mooresboro, North Carolina was disposed of in the northwest corner of Phase 3, Cell
-3- Hazardous Waste Assessment Plan
January 2020
1 of the landfill at the working face. Per communication with the landfill staff, the gypsum
waste was disposed approximately 50-60 feet above the permitted liner system and has
approximately 30-50 feet of additional waste and soil cover material placed on top of the gypsum
waste. The disposal location at the working face was approximately 100 feet by 100 feet on the
days of placement (September 21 and 22, 2020). See Figure 1 for an approximate location of the
gypsum waste.
-4- Hazardous Waste Assessment Plan
January 2020
3.0 UNAUTHORIZED WASTE CONTROL
Incoming waste is observed to verify it is acceptable in content and origin. Accurate and up-to-
date records are maintained for all waste accepted. The following is a general discussion
regarding the waste handling procedures and the types of waste which are accepted at the
landfill, and procedures normally implemented to confirm that only authorized waste is disposed
of at the landfill.
Landfill personnel have been following these procedures and will continue to going forward.
This exceedance occurred due to sample procedures and the timing of American Zinc providing
the sample data after delivery of material based upon on-going sampling. This has been
changed, so that material can only be delivered once sampling is complete and provided to
landfill personnel.
Landfill employees are trained on and required to follow the specific procedures outlined in the
programs referenced below and included in the approved Operations Plan:
• Unauthorized Waste Control Program (see Appendix C, Operations Plan);
• Random Load Inspection Plan (see Appendix C, Operations Plan);
• Asbestos Management and Disposal Plan (see Appendix D; see also Appendix E, Special
Waste Acceptance Procedures of the Operations Plan); and
• Special Waste Quality Acceptance Procedure (see Appendix E, Operations Plan).
All landfill users entering the disposal area are to stop at the entrance gate for security check-in.
All open topped waste loads shall be inspected for hazardous or otherwise unacceptable wastes
by the gatekeeper. An observation platform is provided above the gate house for this purpose.
All other waste loads shall be inspected at the active face by the equipment operators. All trucks
delivering waste to the disposal area shall be weighed. Load weights, customers, and charges to
all vehicles will be recorded. The Landfill will promptly repair and/or replace any
-5- Hazardous Waste Assessment Plan
January 2020
malfunctioning scales. Vehicles will be directed to the appropriate disposal area by signs.
However, verbal or other instructions will be given when necessary.
The Landfill will follow the procedures for incoming inspection, random load inspection and
unauthorized waste response as described in Appendix C, Unauthorized Waste Control Program,
of the permitted Operations Plan.
-6- Hazardous Waste Assessment Plan
January 2020
4.0 WASTE ASSESSMENT
Based on the location and amount of waste disposed, the concentration of the analytical sample,
and other factors below, the proposed management option for the waste is to monitor in-place.
Waste removal is not feasible option based on the following criteria:
Waste Material – The disposed gypsum waste is a powdery substance, placed along with other
municipal solid waste (MSW) at the working face. Due to the intermingling with MSW during
placement, compaction, and covering, it is unlikely that a clear delineation between the MSW
contacted by the gypsum waste can be established. Also, since the material is powdery in nature,
it may have moved vertically and horizontally by water transport from infiltration and moisture
in the MSW around the gypsum material. Since the gypsum material may have mixed
significantly with the surrounding waste material, it is unlikely the powdery material
commingled with traditional MSW could be fully recovered, removed, and relocated with
reasonable certainty without significantly over excavating the MSW.
Waste Placement – The powdery disposed gypsum waste was delivered to the facility in a long-
haul truck and sent to the tipper at the top of the landfill. The gypsum material was off-loaded at
the tipper area and pushed in a “push lane” to the working face with heavy equipment. Based on
the waste material and this placement method, it is unlikely any excavation or removal efforts
would verify complete removal of the gypsum material.
Disposal Location – The gypsum material was placed in a permitted Subtitle D landfill, which
has a composite liner system to prevent groundwater contamination. In the permitted Subtitle D
landfill controls, leachate migration is controlled by a base composite liner system, leachate
collection system (LCS), and final cover system. Downward migration of leachate into natural
groundwater will be prevented by the base composite liner system and LCS. The base liner
system complies with the requirements of 15A NCAC Rule .1624(b) (1) (A), comprising of a
composite liner system and an LCS. The base liner system consists of, from the bottom upward:
-7- Hazardous Waste Assessment Plan
January 2020
Standard Base Liner System
• Compacted soil liner [1 x 10-7 centimeters per second (cm/sec) maximum in-place
permeability, 24 inches thick];
• 60-mil high density polyethylene (HDPE) geomembrane;
• Drainage geocomposite [double sided heat bonded 8 ounce per square yard, 5 x 10-4
square meters per second (m2/sec) minimum transmissivity]; and
• Protective cover (1.9 x 10-4 cm/sec minimum permeability, 24 inches thick) and LCS.
Since the composite liner system is designed to prevent groundwater contamination, the
relatively small amount of material placed that tested above the hazardous waste standard should
not negatively impact the environment or human health.
Material Location – Based on the physical attributes of MSW, it is typically expected to be
stable on a sloped surface at an angle of 3.5:1 (3.5 horizontal feet to 1 vertical foot). Since the
gypsum material was placed up to 50 feet from the current surface of the landfill, any excavation
attempts would involve excavating the MSW placed above the gypsum material in a sloped
fashion away from the gypsum material at this 3.5:1 slope and would result in an area of
excavation of approximately 175 feet wide around the waste placement area. The waste
placement area on the days of disposal was approximately 100 feet by 100 feet. The excavated
working face area plus the layback area for a stable slope would result in an excavation area
approximately 450 feet by 450 feet at the top. This would entail generating roughly 200,000
cubic yards of excavated MSW to simply reach the gypsum material, and the 200,000 cubic
yards of MSW would have to be temporarily stockpiled in another location. When a MSW
excavation operation of this nature is undertaken, there are significant risks to health and the
environment, including potential stormwater contamination, increased vector issues like odor,
dusts, litter, and pests, human health concerns for site staff and contractors, and potential for
leachate outbreaks/spills.
-8- Hazardous Waste Assessment Plan
January 2020
Environmental Assessment - When evaluating mitigation and management options, an
environmental assessment of the benefits and costs should be performed. By monitoring the
waste in-place in the permitted Subtitle D landfill, the Anson County Landfill can minimize
impacts to the human and natural environment. Relocating the gypsum waste would involve
potential health and safety issues for employees, contractors and the significant risks to the
environment. In addition, relocating the gypsum waste would involve excavation of excessive
amounts of MSW material to reach the gypsum waste. Removal efforts would also involve
excavation of the gypsum material, methane management, dust control, transportation to another
facility, and disposal of the waste at another facility. These items would create an additional
overall environmental cost and much more environmental risk compared to monitoring the waste
in-place. Based on these environmental costs and risks, coupled with the inability to confirm
complete removal of the gypsum waste based on the waste type characteristics, disposal location,
placement methods and other factors, monitoring the in-place waste will minimize impacts to
public health and the environment.
-9- Hazardous Waste Assessment Plan
January 2020
5.0 LEACHATE MONITORING PLAN
The facility’s approved Leachate Monitoring Plan has been revised to include sampling leachate
from the sump that collects leachate from the area that the gypsum material was placed. The sump
that serves Phase 3, Cell 1 will be sampled on a quarterly basis until October 30, 2022, when the
facility can resume the normal leachate sampling per the approved leachate monitoring plan. The
facility will continue sampling leachate from the leachate collection system at the storage facility on
a quarterly basis, per the current approved leachate monitoring plan. The constituent containing
concentrations above the hazardous waste standard for the gypsum waste was cadmium, which is
already analyzed as part of the Appendix I Metals analysis in the current leachate monitoring plan.
The Phase 3, Cell 1 sump will be sampled for cadmium and the quarterly leachate storage facility
sample will continue to be analyzed for the 40 CFR Part 258 Appendix I list of constituents,
biochemical oxygen demand (BOD), chemical oxygen demand (COD), nitrate/nitrite, ammonia,
cyanide, mercury, phenolics, phosphorus, sulfate, total Kjeldahl nitrogen (TKN), oil and grease,
and total suspended solids (TSS). The following analytical methods will be used to analyze
leachate samples:
Appendix I VOCs EPA Method 8260 or equivalent method
Appendix I Metals EPA Method 6010 or equivalent method
BOD Standard Method 5210 or equivalent method
COD Standard Method 5220 or equivalent method
Nitrate/Nitrite EPA Method 353.2 or equivalent method
Ammonia EPA Method 350.1 or equivalent method
Cyanide EPA Method 9012 or equivalent method
Mercury EPA Method 7470 or equivalent method
Phenolics EPA Method 420.1 or equivalent method
Phosphorus EPA Method 365.4 or equivalent method
Sulfate EPA Method 300.0 or equivalent method
TKN EPA Method 351.2 or equivalent method
-10- Hazardous Waste Assessment Plan
January 2020
Oil and Grease EPA Method 1664 or equivalent method
TSS Standard Method 2540 or equivalent method
Specific conductance, pH, and temperature will be measured with appropriate and properly
calibrated water quality field instruments.
-11- Hazardous Waste Assessment Plan
January 2020
6.0 SUMMARY
After assessing the gypsum waste material properties, placement methods, the location and depth
of placement, and type of liner system constructed at the landfill, the appropriate management of
the placed gypsum waste material is to monitor in-place with increased leachate monitoring
targeted at the placement area. This management strategy will result in the lowest overall
environmental costs and environmental risks compared to other mitigation or management
options.
FIGURES
8AB3456712CDEFGH83456712ABCDEFGHDESCRIPTIONDATENO
REVISION RECORD
DATE:
DWG SCALE:
DRAWN BY:
CHECKED BY:
APPROVED BY:
PROJECT NO:SHEETOFDRAWING NO.:FIGURE 1
175-033
1"=100'
JANUARY 2021 CTH
NTB
SLB1 NORTHNORTH CAROLINABOARD OF EXAMINERSFOR ENGINEERS ANDSURVEYORS LICENSENO. C-3035CHAMBERS DEVELOPMENT OF NORTH CAROLINA
PHASE 3 CELL 2 BID DRAWINGS
ANSON LANDFILL
ANSON, NORTH CAROLINA
www.cecinc.com
3701 Arco Corporate Drive · Suite 400 · Charlotte, NC 28273
Ph: 980.237.0373 · Fax: 980.237.0372
1 9/20/2019 80% DRAWING SET
2 10/23/2019 ISSUED FOR BIDSREFERENCE
3 11/12/2019 ADDENDUM NO. 1