HomeMy WebLinkAbout0403_CORR_20210429
April 29, 2021
CERTIFIED MAIL 7021 0350 0000 1637 5523
RETURN RECEIPT REQUESTED
Corporation Service Company, Registered Agent
Chambers Development of North Carolina, Inc.
Waste Connections of North Carolina, Inc.
2626 Glenwood Avenue, Suite 550
Raleigh, North Carolina 27608
SUBJECT: Facility Response to Notice of Violation Dated December 15, 2020
Chambers Development MSW Landfill (Anson County)
Permit No. 0403‐MSWLF‐2010
Anson County
Dear Registered Agent,
The State of North Carolina, Division of Waste Management Solid Waste Section (Section) has
completed a review of the facility response to the December 15, 2020, Notice of Violation
(NOV), including the Hazardous Waste Assessment Plan (HWAP) and information requested in
the NOV. The HWAP was submitted by Civil & Environmental Consultants, Inc. (CEC) on behalf
of Chambers Development of North Carolina, Inc., a wholly owned subsidiary of Waste
Connections of North Carolina, Inc., on January 12, 2021.
American Zinc Products, LLC (AZP) reported that on September 21, 2020, and September 22,
2020, approximately 631 tons of gypsum waste were transported from their facility located in
Mooresboro, North Carolina to the Chambers Development Landfill (Anson County) prior to
receiving TCLP analytical results for a composite sample. The laboratory analytical results
showed that the sample contained a concentration of cadmium at 1.1 milligrams per liter
(mg/l), which is above the hazardous waste standard of 1.0 mg/l. Section 1.0 BACKGROUND of
the HWAP states that landfill records showed that a total of 449.77 tons of this gypsum waste
was disposed of in the landfill on September 21, 2020, and September 22, 2020. Subsequently,
the Section requested additional facility records and found that the following loads reported by
Chambers Development of North Carolina, Inc.
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April 29, 2021
AZP as delivered to the facility on September 22, 2020, were reported by the facility as received
on September 23, 2020, with respective tonnages totaling 201.19 tons:
Bill of Lading/Manifest #
41774, 22.11 tons
41780, 22.33 tons
41781, 21.93 tons
41782, 24.50 tons
41783, 19.80 tons
41784, 22.10 tons
41785, 23.37 tons
41786, 21.19 tons
41787, 23.86 tons
Bill of Lading/Manifest #41760 weighing 24.06 tons, showing on the facility report for
September 21, 2020, was not included in the AZP report of approximately 631 tons. With the
addition of the loads received on September 23, 2020, facility records show that a total of 626.9
tons of gypsum wastes reported by AZP as containing cadmium above the hazardous waste
standard of 1.0 mg/l were received between September 21, 2020, and September 23, 2020.
Based on a review of the HWAP and information submitted on behalf of Chambers
Development of North Carolina, Inc., the Section provides the following NOV status and
requirements:
1. The HWAP Section 3.0 UNAUTHORIZED WASTE CONTROL discusses waste acceptance
procedures as described in the facility Operations Plan, with a modification to
procedures to only allow delivery of material once sampling is complete and provided to
landfill personnel. The implementation of actions that will be taken satisfies this
requirement of the NOV.
2. The HWAP Section 2.0 SITE DESCRIPTION and Section 4.0 WASTE ASSESSMENT, with
the revised calculations submitted to the Section on April 16, 2021, satisfies the NOV
requirement to detail the location of the hazardous gypsum waste within the landfill
and provide an assessment of waste removal options and the management of the
waste.
3. The HWAP Section 5.0 LEACHATE MONITORING PLAN was reviewed by Perry Sugg,
P.G., Hydrogeologist. Mr. Sugg approves the monitoring plan. Immediately implement
the plan, and within 10 days of receipt of this letter, submit an addendum to attach to
the current Water Quality Monitoring Plan. Submit the addendum to Mr. Sugg at
perry.sugg@ncdenr.gov. Include the information in Section 5.0 LEACHATE MONITORING
PLAN in the addendum with the quarterly sampling of the Phase 3 Cell 1 sump for
Chambers Development of North Carolina, Inc.
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April 29, 2021
cadmium for 2 years (8 quarters). At the end of the 2‐year period Chambers
Development of North Carolina, Inc. may submit a request to the Section to no longer
monitor for cadmium. Upon receiving the request, the Section will evaluate the data to
determine whether to grant final approval to cease monitoring.
4. The Division may require future actions in the event that monitoring data or other
information indicates harm or potential harm to public health and the environment.
If you have any questions regarding this matter, please contact me at 828‐296‐4702 or e‐mail
deborah.aja@ncdenr.gov.
Sincerely,
Deborah Aja
Western District Supervisor
Division of Waste Management ‐ Solid Waste Section
Copies (via email): Ed Mussler, Solid Waste Section Chief
Jason Watkins, Field Operations Branch Head – Solid Waste Section
Sherri Stanley, Permitting Branch Supervisor – Solid Waste Section
Jessica Montie, Environmental Program Consultant – Solid Waste Section
Perry Sugg, Hydrogeologist – Solid Waste Section
Chris Hollinger, Compliance Officer – Solid Waste Section
Teresa Bradford, Environmental Senior Specialist – Solid Waste Section
Tyler Fitzgerald, District Manager – Waste Connections, Inc.
Nathan Bivins, Project Manager – CEC, Inc.