1010T_NOV_20230301

North Carolina Department of Environmental Quality | Division of Waste Management
217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200

March 1, 2023

CERTIFIED MAIL 7013 0600 0001 7442 0250
RETURN RECEIPT REQUESTED

Ms. Stephanie Lewis, Director of Operations
P.O. Box 249
Bolivia, NC 28422

SUBJECT: Notice of Violation
Compliance Inspection Report
Brunswick County Transfer Station
1010T-TRANSFER-1997
Brunswick County

Dear Ms. Lewis,

On February 20, 2023, Ms. Liz Patterson and Mr. Jason Watkins, representing the State of North
Carolina, Division of Waste Management Solid Waste Section (Section), inspected the above
referenced facility for compliance with North Carolina solid waste statutes and rules. Mr. Jeremy
Baker present and represented Brunswick County Solid Waste during this inspection. The following
violations were observed during the inspection:

1. 15A NCAC 13B .0405 (a)(10) states “Windblown waste: Site staff shall conduct daily
inspections for windblown waste on the site property. Windblown litter from site operations
discovered during the daily inspections or observed on adjacent properties shall be picked
up and containerized for disposal by the end of each operating day, unless the landowner of
the adjacent property denies access to site staff. The site shall prevent waste from being
blown outside the waste handling areas by the wind, using methods such as: (A) requiring
that vehicles entering and leaving the site keep waste covered; (B) providing skirts, such as
rubber belting or brushes, around the top of chutes to minimize the space between the chute
and the hauling trailer at sites with chutes and hoppers; or (C) preventing waste from leaving
the site using methods such as fencing, netting, or diking.”

During the inspection windblown waste was observed on the east side and north side of the
transfer station. Transfer trailers were being tarped before all waste was inside. Excessive
amount of waste was accumulating in the loading bay.

2. .15A NCAC 13B .0405 (b), “Water that comes into contact with solid waste is leachate
and shall be collected from the site for disposal to an approved facility or discharged
directly from the site into a sanitary sewer line.

North Carolina Department of Environmental Quality | Division of Waste Management
127 Cardinal Drive Ext. | Wilmington, North Carolina 28405
910-796-7215

Brunswick County Transfer Station
Notice of Violation
Page 2 of 3
March 1, 2023

”Permit to Operate, Attachment 3, Part VI (23), “All water or liquid that comes
in contact with solid waste, including vehicle wash-down water is leachate and
must be captured and properly treated before release into the environment.”

At the time of inspection, leachate was observed ponding on the east side of the
transfer station in front of the cardboard area.

The Brunswick County Transfer Station is in violation of 15A NCAC 13B .0405 (b) and Permit
to Operate, Attachment 3, Part VI (23) in that leachate has not been properly captured and
treated prior to release into the environment. At the time of this inspection, leachate was
observed ponding on the east side of the transfer station. The ponding leachate was identified
to be outside of the leachate collection system.

Based upon the foregoing, upon receipt of this Notice of Violation, Brunswick County shall come into
compliance with all applicable requirements of the regulations in 15A NCAC 138 .0405 and the
Permit to Operate by completing the following:

1. Immediately takes steps to collect all windblown waste and relocate it to the transfer
station for disposal.
2. In response to the leachate releases, identify the cause of the releases and take action to
stop the release.
3. Submit a Sampling Plan for Section approval prior to sampling. The proposed plan shall
be submitted in electronic format sent via email and meet the following requirements:
• Include a description of the release incident (source, dates, size of known impact, etc.).
• Include a map/aerial photo depicting area of impact and proposed sampling locations.
• Provide a description of the proposed sampling methodology.
• Describe the proposed subsurface soil sampling and surface water sampling (if
applicable) at specific locations, including background soil and upstream water locations.
The sampling plan must fully evaluate the extent of the potential environmental impacts
from the release(s) at the facility and include, at a minimum, the following sampling
requirements:
i. subsurface soil samples shall be collected between one to two feet below
ground surface,
ii. discrete soil samples shall be collected (composite samples will not be
accepted), and
iii. all soil and surface water samples shall be analyzed by a NC certified
laboratory for 40 CFR Part 258 Appendix I parameters (VOCs and Total
Metals), 1,4-dioxane, total phosphorus, sulfate, nitrate, and pH.
4. After Section approval of the sampling plan, the plan shall be implemented within seven
(7) days. Within 10 business days after receiving the analytical results from the
laboratory, submit documentation regarding the sampling event which shall include the
following:
a. A summary of the leachate release, actions taken to address the release, and the
release assessment;
b. A map/aerial photograph depicting the sampling locations;
North Carolina Department of Environmental Quality | Division of Waste Management
127 Cardinal Drive Ext. | Wilmington, North Carolina 28405
910-796-7215

Brunswick County Transfer Station
Notice of Violation
Page 3 of 3
March 1, 2023

c. A table of the surface water analytical results compared to the NCDWR Surface Water
Quality Standards & Protective Values;
d. A table of the subsurface soil analytical results compared to the NCDEQ Preliminary
Soil Remediation Goals (PSRGs) must be met;
e. The associated laboratory reports from the NC certified laboratory including the
chain of custody and QA/QC results;
f. The sampling methodology, if different from the proposed plan; and
g. Conclusions and recommendations

All corrective measures must be completed within 30 days' receipt of this notice of violations. A
follow up site inspection will be conducted after 30 days have passed to ensure that the corrective
measures have been completed to bring this facility into compliance.

The violations 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.

Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct a
follow-up inspection to verify that the operator has completed the requirements of this Notice of
Violation.

If you have any questions, please contact me at 910-796-7405 or e-mail
[e-mail].

Sincerely,

Liz Patterson
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section

copies: Jason Watkins, Field Operations Branch Head- Solid Waste Section
Drew Hammonds, Eastern District Supervisor - Solid Waste Section
Chris Hollinger, Compliance Officer - Solid Waste Section
Elizabeth Werner, Hydrogeologist - Solid Waste Section
Jeremy Baker, Landfill Supervisor ([e-mail])
Steve Stone, Brunswick Co Manager ([e-mail]