7607_INSP_20220310

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 8
UNIT TYPE:
Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: Randolph
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 76-07
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: March 10, 2022 Date of Last Inspection: August 5, 2021
FACILITY NAME AND ADDRESS: Great Oak Landfill 3597 Old Cedar Falls Road Randleman, NC 27317 GPS COORDINATES:
N: 35.752822 W: -79.755992 FACILITY CONTACT NAME AND PHONE NUMBER:
Mike McFeeley, District Manager, Great Oak Landfill – Waste Management c. 336-865-3201 [e-mail]
FACILITY CONTACT ADDRESS: Waste Management of Carolinas, Inc. (Operator) Mike McFeeley, District Manager, Great Oak Landfill – Waste Management 3597 Old Cedar Falls Road Randleman, NC 27317

Randolph County (Owner) Randolph County Office Building 725 McDowell Road Asheboro, NC 27205

PARTICIPANTS:
Chuck Kirchner, Environmental Specialist II - Solid Waste Section (SWS) Mike McFeeley, District Manager, Great Oak Landfill – Waste Management Bobby Owens, Landfill Operations Manager, Great Oak Landfill – Waste Management Kyle Mertens, Environmental Protection Manager – Waste Management Susan Harrison, Area Engineering Manager – Waste Management
STATUS OF PERMIT:
Permit To Operate (PTO) issued October 15, 2020 Permit To Construct (PTC) Phase 1, Cell 6 & 7 issued in conjunction with PTO issued October 15, 2020 PURPOSE OF SITE VISIT:
Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS:
None
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 8
OBSERVED VIOLATIONS:
A. 15A NCAC 13B .1626(2)(b) Cover material requirements states in part: “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 prevent the escape of waste and the attraction of vectors and scavenging, and to minimize fires and the generation of odors.”

View of exposed waste below Phase I, Cell 4 on north side of current working face. Photograph by Chuck Kirchner during 3/10/22 site inspection.

During the inspection, a large amount of exposed waste, in an area estimated to be 1.5 acres in size, was observed below the tipping area on the north side slope of the active cell. Therefore, the County of Randolph, N.C. and Waste Management of Carolinas, Inc. are in violation of 15A NCAC 13B .1626(2)(b) by failing to cover disposed solid waste with six inches of earthen material at the end of each operating day. To achieve compliance, the County of Randolph, N.C. and Waste Management of Carolinas, Inc. must cover disposed
solid waste with six inches of earthen material and/or an approved alternative daily cover material at the end of each operating day. Compliance must be demonstrated by April 8, 2022. A follow-up inspection will be performed to verify compliance.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 8
B. 15A NCAC 13B .1626(8)(d) states in part: “Leachate shall be contained within a lined disposal cell or leachate
collection and storage system. All leachate shall be treated, as required by the receiving facility, prior to discharge.” During the inspection, a leachate release was observed in the low area between the lined cells 3A and 3B and the unlined
cell 6 under construction. Leachate mixed with stormwater flowed from the lined landfill cells into the low area of cell 6. Leachate was observed spread out in the low area of cell 6. Leachate was observed near the stormwater outlet of cell 6. (see post inspection meeting in the comment section below for further details)
The County of Randolph, N.C. and Waste Management of Carolinas, Inc. are in violation of 15A NCAC 13B .1626(8)(d) in that leachate was not contained within the lined disposal cell or leachate containment and storage system.
View of leachate release in Phase 1, From Cell 3-5 into Cell 6. Photographs by Chuck Kirchner during 3/10/22 site inspection.

View of leachate release into Phase 1, Cell 6. Photograph by Chuck Kirchner during 3/10/22 site inspection.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 8
To achieve compliance, within 10-days of receipt of this inspection report, Waste Management and Randolph County must make all necessary repairs between Phase 3-5 and Phase 6 to prevent the further release of leachate and leachate mixed with stormwater off the lined cell. Waste Management and Randolph County submitted a Sampling and Analysis Plan on March 18, 2022 to determine the impact of the leachate release. Any additional corrective measures must meet requirements set forth by Solid Waste Section Hydrologist, Christine Ritter and the requirements set forth by Ming-Tai Chao, Permitting Engineer. No further construction activities may take place in Cells 6 & 7 unless approved by the Section. Additionally, submit a plan for enhanced actions that will be taken to provide oversight of site activities and ensure that leachate, and leachate mixed with stormwater, is properly contained. Submit the plan to Chuck Kirchner at [e-mail].

C. 15A NCAC 13B .1626 (11) states, in part: "At the conclusion of each day of operation, all windblown material resulting from the operation shall be collected and disposed of by the owner or operator." During the inspection, windblown waste was observed below the tipping area on the north side slope of the active cell. The County of Randolph, N.C. and Waste Management of Carolinas, Inc. are in violation of 15A NCAC 13B .1626(11) by failing to collect and return all windblown material to the active landfill at the end of each day.
To achieve compliance, the County of Randolph, N.C. and Waste Management of Carolinas, Inc. must collect and return all windblown material to the active landfill at the end of each day. Compliance must be demonstrated by April 8, 2022. A
follow-up inspection will be performed to verify compliance.
View of windblown litter on north side of Phase I, Cell 4. Black trash bags on slope in this photograph are from windblown litter collected from the previous day. Photograph by Chuck Kirchner during 3/10/22 site inspection.

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

Page 5 of 8
ADDITIONAL COMMENTS
On March 10, 2022, Chuck Kirchner met with Mike McFeeley, Bobby Owens, Kyle Mertens, Susan Harrison and others
to conduct a pre-construction meeting of the Phase 1, Cell 6 & Cell 7 leachate line and cell liner installation. Ming Tai Chao attended the pre-construction meeting via phone. A comprehensive inspection of the Great Oak Landfill on Old Cedar Falls Road in Randleman, Randolph County was conducted during this facility visit following the pre-construction meeting. Facility Information 1. The Great Oak Landfill is a municipal solid waste (MSW) landfill owned by Randolph County and operated by Waste Management of Carolinas, Inc. 2. The facility is in operation Monday through Friday 7:30 am to 5:00 pm and Saturday 7:30 am to 12:00 pm.
3. The facility is permitted to receive solid waste from within the State of North Carolina. 4. The facility does not accept scrap tires or white goods. These were not observed on site during the inspection. 5. In phase 1, cell 6 and cell 7 have been excavated and are to grade. A clay base layer was observed this inspection.
Contractors are on site and are ready to install leachate line and liner for cell 6 & 7. Work is expected to take about a month to complete. 6. Cell 6 and Cell 7 will add 9.8 acres of disposal area to the landfill.
7. The facility has constructed Phase 1, Cell 1A, 1B, 3A, 3B, 4 and 5. 8. Waste Management is currently operating in Cell 4. According to Mr. McFeeley, Cell 3A, 3B & 4 are at about 75% capacity. Records Review 9. The permit and operations plan were discussed during this inspection. 10. The facility annual report (FAR) was received by the SWS dated July 27, 2021. Facility throughput for July 2020 through June 2021 is 643,035.85 tons which is up from 599,028.95 tons on 2019-2020 annual report. 11. The facility maintains daily and monthly records of the amount of solid waste received. Facility records were observed for July 31, 2021, through December 31, 2021. The facility received 351,351.30 tons of waste during that timeframe. 12. Great Oaks Landfill has an Erosion and Sediment Control Permit with NCDEQ, DEMLR, permit number: RANDO-2019-026.
13. The facility has a stormwater National Pollutant Discharge Elimination System (NPDES) permit, General Permit No. NCG120000, Certificate of Coverage No. NCG120107. The NPDES permit expires on June 30, 2026. 14. On April 24, 2018, the facility was issued a Division of Air Quality (DAQ) Title V permit No. 10446T04,
expiration date February 28, 2026. 15. The facility has an Industrial User Permit, Permit number 4953, from the City of Asheboro to discharge wastewater. The permit expires on July 21, 2026. 16. The facility maintains semiannual groundwater and surface water monitoring and leachate test records submitted by Golder Associates NC, Inc., and analyzed by Eurofins TestAmerica out of Arvada, Colorado. Records were observed for groundwater and surface water monitoring and leachate testing conducted on May 11-12, 2021 for the First Semi-annual 2021 sampling and on October 5, 2021 and December 9, 2021 for the Second Semi-annual 2021 sampling. An exceedance was indicated on each report.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 8
17. Certified Personnel Records: a. Jeff Garner Certified LF Operations Specialist # LF-2020019, expires 3/17/2023 b. Vanessa Hemphill Certified LF Operations Specialist # LF-2017052, expires 6/28/2023 c. Randy White Certified LF Operations Specialist # LF-2017051, expires 6/28/2023 d. Darren Wilson Certified LF Operations Specialist # LF-2017049, expires 6/28/2023 e. Bryan Wall Certified LF Operations Specialist # LF-2017047, expires 6/28/2024
f. Daniel Bowland Certified LF Operations Specialist # LF-2017044, expires 9/28/2024 g. Lisa Thompson Certified LF Operations Specialist # LF-2021006, expires 3/9/2024 h. Mike McFeeley Manager of LF Operations # 1397982, expired 9/15/2023 i. Bobby Owens Manager of LF Operations # 1408090, expired 9/15/2023 18. The facility is required to conduct a waste screening on a minimum of 1% of commercial and industrial loads received. Records from January 4, 2021, through March 9, 2022 were observed.
19. Mr. Owens stated that Great Oaks Landfill typically conducts two waste screenings per day. 20. The facility conducts landfill gas (LFG) monitoring at 4 monitoring wells. Landfill gas monitoring well observed during this inspection was maintained in an accessible condition. 21. LFG Quarterly Records observed for March 5, 2021, and June 17, 2021, September 27, 2021 and December 27, 2021. No methane or hydrogen sulfide detected at monitoring points MMW-1-4. 22. Landtec GEM5000 gas meter, S/N G504615, was last calibrated on July 30, 2021, by QED Environmental Systems, Inc. 23. Asbestos Disposal Log reviewed for February 28, 2017, through January 13, 2022. All asbestos disposal areas latitude and longitude have been recorded. 24. Leachate lines were flushed and had a partial video inspection last documented on September 3, 2020. Covanta Vac Truck was used to pull sediment material out of leachate lines.
25. Mr. McFeeley stated he would like to start having the leachate lines videoed and flushed one section of the landfill at a time and have it a part of the annual budget. Mr. McFeeley stated additional maintenance is performed regularly as needed.
26. Leachate storage tank inspection records and weekly sump records were reviewed from January 4, 2021, through
March 1, 2022. 27. During the inspection the leachate tank was noted to have 6.0’ of leachate in the tank. The tank has a continuous overflow discharge to the City of Asheboro Wastewater Treatment Plant. The leachate tank was observed to be in good condition during this inspection.
28. The City of Asheboro conducts monthly sampling of leachate to test for constituents according to Mr. Owens. Site Inspection
29. The facility has proper site access, security, signs, and safety requirements. 30. Yellow Edge of Waste (EOW) markers observed this inspection.
31. No prohibited wastes observed in the working face this inspection. 32. The landfill was operating two tippers and has a convenience center on the south side of Phase 1 for residential drop off.
33. Maintain working face as small and compact as possible as discussed in the field. 34. Working face uses foam alternative daily cover (ADC) and auto fluff ADC. 35. Along the south side of the top of the landfill near the current working face a large fence to collect windblown litter has been installed. No windblown litter was observed along the southern slope of the landfill. 36. Windblown waste was observed below the tipping area on the north side slope of the active cell. Several apparently full black trash bags observed on northern slope of the landfill. Waste Management stated that these bags were from a previous day’s windblown litter collection and the rains prevented them from being disposed of. See Observed Violations section of this report. 37. Inadequate daily cover observed on northern slope of Cells 3-5. This cover had a high percentage of rocks, and apparent washing of fines exposing waste. See Observed Violations section of this report.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 8
38. A spray odor control system has been installed and was in operation during this site visit. Spray tubing is attached to the fencing to catch windblown material south of the working face. 39. Continue to stabilize areas with bare or sparse grass cover until vigorous permanent grass cover germinates, especially in areas that will not be disturbed for over one year. Rills along the south slopes are getting close to exposing waste. Ensure these rills are repaired and stabilized in a timely manner. General Comments 40. The volume of waste disposal shall not exceed an average daily intake and disposal rate of 4,000 tons per day or a maximum daily intake and disposal rate of 5,500 tons per day to account for times when intake rate may peak. According to Mr. McFeeley recent average daily disposal rate is 2,000 tons per day. 41. The permittee shall implement a program for collecting, removing, and properly disposing of windblown litter or wastes daily at the areas inside the landfill facility and site entrance and the roads leading to the site entrance according to the Amended and Restated Agreement effective April 1, 2019 (FID 1322196).
42. Landfill gas collection system to flare observed being installed by B&M Excavation this inspection.
View of landfill gas flare located near basin east of Phase 1. Photograph by Chuck Kirchner during 3/10/22 site inspection.

43. The operations plan states that the facility may use reusable tarps, auto-shredder fluff, and petroleum contaminated soil as ADC. Mr. McFeeley stated that automotive shredder residuals (ASR) and spray-applied mortar coating (SMC) are mainly used for daily cover with soil being used on outer slopes. 44. Erosion, drainage, and sedimentation controls observed appeared to be in good order. 45. Sediment basins are required to be cleaned out when sediment accumulates to ½ of the design depth as specified in the facility operations plan. 46. Ensure bare areas are stabilized per NPDES and NCDEMLR requirements. 47. The facility has a permanent truck wheel wash. 48. The Randolph County Fire Department can be contacted to respond to an emergency at the facility. 49. Access roads are of all-weather construction. 50. The facility has proper signage.
51. The facility entrance is secured by a metal gate with lock. 52. Please contact me if you have any questions or concerns regarding this inspection report.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 8
Post Inspection Meeting 53. During a meeting between the Section and Waste Management on March 11th, further information was shared regarding the release into cell 6. Waste Management staff asserted that the release was not leachate coming from the waste mass itself, but from a combination of stormwater comingled with leachate from the side slope of the
landfill, that left the active cell due to the absence of, or partial collapse of a berm installed by the contractor locating the edge of liner for tie in. Photos were shared during the meeting to support this position. 54. Prior to the meeting, the Section received the subgrade certification report for cells 6 & 7. As discussed in the meeting and in subsequent communication between parties, cell 6 certification is delayed pending full cleanup and restoration of the areas impacted by the release. No decision has been made on whether cell 7 will be allowed to proceed.
________________________________________ Phone: [phone] or email: [e-mail] Chuck Kirchner
Environmental Specialist II Regional Representative
Sent on: March 22, 2022 X Email Hand delivery US Mail X Certified No. [ _]
Copies: Jason Watkins, Field Operations Branch Head – SWS
Deb Aja, Western District Supervisor - SWS Ming-Tai Chao, Environmental Engineer – SWS Christine Ritter, Hydrogeologist - SWS Kyle Mertens, Environmental Protection Manager -Waste Management (c. 321-403-2544, [e-mail]) Susan B. Harrison, Engineer, South Atlantic Area – Waste Management (c. 678-436-2719, [e-mail])
Hal Johnson, County Manager, Randolph County, [e-mail]
Paxton Arthurs, Engineer - Randolph County Public Works (c. 336-736-7927, [e-mail])