2615-LCID-2022_INSP_20221110

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID X YW X Transfer Compost SLAS COUNTY: Cumberland
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 2615-LCID-2022
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: November 10, 2022 Date of Last Inspection: November 10, 2021

FACILITY NAME AND ADDRESS:
Wilkes Rd. LCID Landfill Wilkes Road Fayetteville, North Carolina GPS COORDINATES: Lat: 35.06444 Long: -78.87106 FACILITY CONTACT NAME AND PHONE NUMBER: Amanda Bader, SW Director, CCSW
Tim Middleton, Facility Supervisor, CCSW [e-mail] 910-321-6835
FACILITY CONTACT ADDRESS:
Office of Solid Waste, 698 Ann Street, Fayetteville, NC 28301
PARTICIPANTS: David Powell, Solid Waste Section Drew Hammonds, Solid Waste Section Amanda Bader, CCSW Neil Cunningham, CCSW Mike Renfro, CCSW Tim Middleton, CCSW Scott Bost, Smith and Gardner Stacey Smith, Smith and Gardner Troy lee, Lorman Grading
STATUS OF PERMIT:
LCID 26-F closed in 2011. 0.56-acre area over LCID was approved for additional storage, of leaf debris from 2610-Compost, in July of 2015. Current Permit To Construct and Permit To Operate 2615-LCID-2022, (Previous CLOSED Permit 26F-LCID-1986) Issued September 1, 2022, and expires June 29, 2030; Currently Phase 1 (4 Acres) will be permitted to operate.
PURPOSE OF SITE VISIT: Pre-Operational Inspection

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 9
STATUS OF PAST NOTED VIOLATIONS: NA OBSERVED VIOLATIONS:

1. Permit Attachment 2, Part V, 11 – The following is required prior to receiving solid waste in the new phase:
a. Written certification from a registered professional engineer must be submitted to the Section certifying that the waste disposal unit(s) has been constructed in accordance with the approved plan. b. The disposal unit boundary must be accurately delineated with permanent markers in accordance with 15A NCAC 13B .0201(g).
c. Prior to receiving waste at the new constructed cell or phase of the landfill, a site inspection and pre-operative meeting may be conducted by a representative of the Section per Rule 15A NCAC 13B .0203(c). The permittee must notify the Section’s Senior Environmental Specialist and make arrangements for the site inspection and pre-operative meeting. d. After completion of the requirements in subparagraphs a. through c. above, the Section Senior Environmental Specialist will notify the Permitting Branch Supervisor by a letter or an email that the pre-operative requirements have been met and that the unit(s) may commence receiving waste. The permittee will be copied on the notification and may begin receiving waste at that time.

2. Permit Attachment 3, Part V, 16 - Revisions to the design or operation of the facility require written approval of the Section and may be subject to a permitting fee.
In recent months, fires have been reported at Wilkes Road Facility, one on 9/28/2022 and again on 10/28/2022.
The fire on 9/28/2022 was an electrical fire on a bulldozer. The fire on 10/28/2022 was in a large pile near center of facility being processed and grinded, before composting. This last fire caused a problem with operations at Wilkes Road Compost side of facility. According to CCSW, operations needed to be moved for space and fire containment/management. However, a preoperational inspection had not been conducted by that time for the newly permitted LCID. During the 11/10/2022 inspection, it was determined that all conditions for pre-operation were not met and not all structures/units were constructed according to approved plans. Although, during email conversations between fire notifications and the 11/10/2022 inspection, Cumberland County and its representatives discussed moving operations to atop the newly permitted LCID,
permission was not given or approved at that time to do so. Mr. Powell had not submitted notification to Section permitting that the site met preoperational conditions and an engineer certification letter had not been received by the Section. Due to these events, a Notice of Deficiency will follow this 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 3 of 9
Stormwater Pond / Sediment Basin future location marked. Also, some waste piles need removal to MSWLF on left in frame.
YW acceptance, processing, and storage operations moved from compost facility to LCID, along with LCID cap removal/storage and soil screening.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 9
ADDITIONAL COMMENTS

1. From 1986 to 1992, a demolition landfill operated on this property, permitted as 26F. Most of the waste from that is in the approximate area of the western end of the LCID. The demolition landfill was later called an 26F-LCID (land clearing and inert debris) landfill and was certified closed in May 2011. In 2022, a new LCID
landfill, permit 2615-LCID-2022 in conjunction with 2610-COMPOST-2011, has been permitted at the site of the Wilkes Rd Facility. Records were reviewed on 11/14/2022 at CCSW office, but the records were available at the Wilkes Road facility as required, to allow for an easier review of records for this and other facilities of the
county. 2. Section staff David Powell met with CCSW, Smith and Gardner and Lorman Grading staff onsite at
Compost/LCID Wilkes road facility for a pre-operational inspection and a comprehensive inspection. Site has fence and gate. 3. Mr. Powell walked the Wilkes Road facility with onsite representatives and discussed fire, current operations and changes to operations since fire. A storm water pond / sediment basin on LCID side is not constructed according to approved plans, although markers are present for its location. Some waste needs removal from this area to Ann St, MSWLF waste and a tire currently located here. CCSW and Smith and Gardner believed this could be constructed later as operation grew. Mr. Powell indicated this pre-operation inspection was to confirm all units/structures were constructed and installed according to approved plans/permits and ready for operation. Given the current state of the facility, with not having all units constructed and installed, the site has not met all permit requirements for pre-operational conditions. After discussion onsite between Mr. Powell
and CCSW, Drew Hammonds arrived, and he elaborated on the permit and the preoperational conditions. Mr. Hammonds and Mr. Powell rode site once more and reviewed the permit/approved plans. It was determined that the site didn’t have all units installed/constructed and a Notice of Deficiency would be submitted for operating to early and before the Section gave approval with the current operations onsite. Mr. Hammonds explained that the Section understood the county had to adjust operations, but the county should have had reached out to the Section on how to proceed, what options were available, and what may be needed to
alter those operations. Section staff instructed CCSW staff to submit a permit modification or temporary request to operate and move forward with current operations. Contact Jordan Russ, Section Permitting, 919-707-8229 or [e-mail].

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 9
Soil cap removed and stockpiled adjacent excavated cap area where YW is accepted.
YW area, screening of soil cap on right, all activities on top LCID.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 9
4. Upon discussion with Mr. Middleton, he indicated that the LCID cap had been removed, which is
approximately 2-foot-deep x 100-foot-wide x 150-foot-long, and set to the side, while the excavated area is used for accepting new yard waste. The county is processing the cap cover, and screening it, and the soil is intended to be used as cover at Wilkes LCID or Ann St landfills. This current operation conflicts with LCID rules/permit in regard to cover with no less than six inches of soil monthly or when the active area reaches one (1) acre in size, whichever occurs first. On 11/11/2022, Smith and Gardner, on behalf of CCSW, sent a letter to Section Permitting, requesting to approve and confirm onsite operations and plans moving forward. On 11/16,2022, Jordan Russ, Section Permitting, responded with a letter outlining the approved changes, outlines responses, plans and needs from CCSW moving forward. Section Permitting has approved, in part, temporary operational changes to atop the LCID, what is needed to return to normal operations, the use of ash as daily cover, once fire is confirmed out, and soil recovered from LCID at Wilkes be used as cover at Ann St and Wilkes LCID facilities.
5. Around the LCID, Edge of Waste (EOW) markers were installed and visible, good job. Side slopes could use some mowing but were not too overgrown and slope was good. There were, however, some severe ruts on
north slope, please address when conditions permit. A seep was visible on north side just down from soil screening area, please address and do not allow discharge of leachate.
EOW markers and side slopes.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 9
Ruts on north side slope.
Along north side, just down from screening area, is a seep. Please address and do not let leachate discharge. Additional mowing will assist with identifying seeps around perimeter.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 9
6. All preoperational conditions should be met as described in permit, and new recommendations from Jordan Russ letter dated 11/16/2022 before a request for a follow up inspection to confirm site is finished and ready to operate according to submitted and approved plans.
Western end of old LCID, demolition area in rear.

South side slope of LCID, just past cap soil storage.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 9
7. Given the fires, which caused the need for operational changes, and boilers not accepting wood fuel, it has added much increased demand on both the compost facility and the new LCID facility. The county needs to improve or expand its contingency plans to account for such incidents. These events and problems show areas of need in increased space and avenues for utilizing the product created through Wilkes Road. If the county cannot operate inside of the limits of the permit, rules and approved plans, then changes need to be made onsite or services altered to fit them. 8. Corrective actions are necessary as result of this inspection. Corrective actions should be completed within 30 days from the date of this inspection report sent. Failure to resolve these matters may result in further enforcement action. A follow up may be conducted once these issues are addressed in the given time frame or shortly after.
Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone]_____ _ David Powell
Environmental Senior Specialist Regional Representative
Sent on: 12/9/2022 X Email Hand delivery US Mail Certified No. [ _]
Copies: Drew Hammonds, Eastern District Supervisor - Solid Waste Section
Jordan Russ, Engineering Project Manager – Solid Waste Section Sherri Stanley, Permitting Branch Supervisor - Solid Waste Section