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HomeMy WebLinkAbout2608CDLF1998_INSP_20240125FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 11 UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Cumberland Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 2608-CDLF-1998 CDLF X Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: January 25, 2024 Date of Last Inspection: March 23, 2021 FACILITY NAME AND ADDRESS: Fort Liberty C&D Landfill Lamont Road, Fort Liberty GPS COORDINATES: Lat.: 35.145415 Long.: -79.072703 FACILITY CONTACT NAME AND PHONE NUMBER: Name: Shawn C. Hardy, Solid Waste Manager Telephone: 910-396-2295 Email address: shawn.c.hardy.civ@mail.mil Fax: 910-396-4188 FACILITY CONTACT ADDRESS: Department of the Army Department of Public Works 2175 Rock Merritt Ave Stop A AMIM-LIP-EC (Attn: Shawn C. Hardy) Fort Liberty, NC 28310 PARTICIPANTS: David Powell, NC DEQ, Solid Waste Section Andrew Hammonds, NC DEQ, Solid Waste Section James “Jim” Duncan, DPW, Environmental Compliance Branch Shawn Hardy, DPW, Environmental Compliance Branch Daniel Messier, DPW, OMD Brian Locklear, Engineering Div., DWP STATUS OF PERMIT: PTC Phase II/Closure of Phase I April 28, 2011; PTC Phase II issued March 19, 2012; PTO Phase II/Close Phase I issued September 22, 2014; PTC Phase III, PTO Phase I & II, permit for Closure Phase I (partial) issued May 10, 2016. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: NA OBSERVED VIOLATIONS: NA FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 11 ADDITIONAL COMMENTS 1. The purpose of the visit was to inspect the CDLF for closure, view the closed MSW and the recycling area over the closed LCID. Section staff Andrew Hammonds and David Powell met with Fort Liberty Staff, Shawn Hardy, Jim Duncan, Dan Messier and Bryan Locklear. The site is on a U.S. military base, behind locked gate and fence with all- weather roads. Closure for CDLF was discussed, as well as recent conference call with Fort Liberty staff and Section staff, mainly Claire Osborn and what her comments outlined on a submitted document sent to Brian Locklear on January 25, 2024. The site was visited, perimeter was toured via vehicle and visually inspected and partially walked by all in attendance for the 1/25/2024 inspection. Cap and Closure of CDLF was discussed to determine a plan for a path forward that will meet all closure requirements successfully. Fort Liberty Staff should communicate with Claire Osborne with Section permitting and be sure all required documents are submitted and closure can proceed before any onsite work begins. Entrance to facility on base. 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 11 2. Previous identified issues onsite were as follows: The previous borings could not be certified. An additional 90 borings were done, of which 9 had permeability issues. 19 other areas didn’t have the specified cover thickness; Alternatives were discussed, and possible equivalencies were suggested by Sanitec. Previously comments by Sherri Stanley, Section Permitting Branch Supervisor, explained that she is unsure if equivalencies can be done on these issues, such as the requirement for 1.5-foot permeability layer. On January 17, 2024, there was a team’s meeting with Fort Liberty Staff and Section Staff Claire Osborne, the engineer for Section permitting and David Powell, inspector for Section, to discuss updates, determinations and comments from Section permitting based on what has been to date from Fort Liberty. Ms. Claire discussed what was needed by Fort Liberty and outlined commentsthat the group should research and respond too accordingly. A follow up letter was sent to Bryan Locklear, Fort Liberty Project Manager of DPW, from Ms. Claire, to summarize those comments, questions, and determinations. Please follow up with the appropriate responses to this document. Please continue to communicate with NCDEQ Permitting staff on these requirements. Contact Information for Section Engineer Claire Osborne at claire.osborn@deq.nc.gov or 828 – 296 - 4706 office. 3. As it sits, currently the CLDF had 2 complete phases but started closing the facility before beginning in phase 3. It was determined last inspection that an extension request should be submitted in writing, if not done so, per 15A NCAC 13B .0543(c)(6) and Permit to Operate Attachment III, Part III #23. This was done for the Transfer Station, but CDLF needs a request as well. Ft. Liberty shall contact Claire Osborne for all closure QA/QC and report requirements to avoid violation of 15A NCAC 13B .0543(c)(7): Following closure of each C&DLF unit, the owner or operator must notify the Division that a certification, signed by the project engineer verifying that closure has been completed in accordance with the closure plan, has been placed in the operating record. Ft. Liberty also, if not already done so, needs to submit an updated drawing showing the limit of CD waste asbestos disposal areas need to be identified on the CDLF maps, final elevation and the areas of the facility to be utilized for recycling purposes. Some of these items were discussed at the last onsite meeting. In fact, some of the work has been completed based on onsite conversations, but the documentation and notification need to be submitted to Solid Waste Permitting. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 11 4. Section staff noticed a small area on SE cap that water impounded over waste. Please be sure and address this and any other areas in which have settled. 15A NCAC 13B .0543 (e)(1)(A) maintaining the integrity and effectiveness of any cap system including making repairs to the cover as necessary to correct the effects of settlement, subsidence, erosion, or other events, and preventing run-on and run-off from eroding or otherwise damaging the cap system. SE side of CLD with settled area. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 11 5. Ft. Liberty did not enter Phase 3 or 4 before deciding to close. The sedimentation pond onsite still looks good. 6. There was an area of the slope on the North side of Phase 2, along the back that had previously sloughed off despite erosion control measures. The slope should be repaired as soon as possible, but when conditions allow, to prevent additional slope failure and erosion. Discuss with consultant on methods for repair in conjunction with meeting cap/closure requirements. Sloughed area from distance. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 11 Close up view of sloughed area needing repair. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 11 7. The perimeter side slopes were in good condition, well vegetated and mostly mowed with no erosion other than the sloughed area. Vents looked good from a distance as well. The top of CDLF was also viewed from NW corner. Signage for asbestos and EOW markers were in place. Good job. Top of CDLF from NW corner. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 11 SW side slope near office. The view is from NW side of center of CDLF. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 11 East side slope and roadway. S side area, also where asbestos disposal is located. Signage is still present. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 11 8. Several wells were visited during inspection, including: GP3, MW-6, GP-14 AND GP2. All seemed to be in good shape, had locks and ID plates. Good job. Army Corp of Engineers (ACOE) does sampling/monitoring and they have been working with Sections Ervin Lane. Mr. Powell spoke with Mr. Lane to confirm all requirements are being met for Section in regard to sampling. GP2 GP14 9. Corrective measures are necessary as a result of the inspection findings and shall be completed within 30 days’ receipt of this report. Failure to ensure corrective measures are complete may result in further compliance actions. Please contact me if you have any questions or concerns regarding this inspection report. ________________________________________ Phone: 919 – 280 - 5135 _ Environmental Senior Specialist Regional Representative Sent on: 2/5/2024 X Email Hand delivery US Mail Certified No. [ _] FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 11 Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Supervisor – Solid Waste Section Claire Osborne, Environmental Engineer – Solid Waste Section Ervin Lane, Hydrogeologist – Solid Waste Section