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HomeMy WebLinkAbout4204__Halifax_INSP_20170808FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 4 UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Halifax Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 4204-INDUS-1994 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill X DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: August 8, 2017 Date of Last Inspection: December 1, 2016 FACILITY NAME AND ADDRESS: Halifax Coal Ash Landfill 921 Liles Road Halifax, NC 27839 GPS COORDINATES: N: 36.38029 W: -77.81138 FACILITY CONTACT NAME AND PHONE NUMBER: Ed Stanfield, Tel- 252-586-7516, stanfielde@halifaxnc.com Greg Griffin, Tel- 252-583-1451, griffing@halifaxnc.com FACILITY CONTACT ADDRESS: Halifax County Industrial Coal Ash Landfill PO Box 70 Halifax, NC 27839 PARTICIPANTS: Ed Stanfield, Halifax County, Landfill Supervisor Greg Griffin, Halifax County, Director of Public Utilities Shawn McKee – NCDEQ, Solid Waste Section Elizabeth Werner – NCDEQ, Solid Waste Section STATUS OF PERMIT: Active. Permit 4204-INDUS-1994 was issued on March 27, 2012 and expired on March 27, 2017. A request to the Section for permit review has been submitted and is pending review. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: 15A NCAC 13B .0505 (3)(b) “Areas which will not have additional wastes placed on them for 12 months or more, but where final termination of disposal operations has not occurred, shall be covered with a minimum of one foot of intermediate cover.” On October 20, 2015 the Division of Waste Management, Solid Waste Section (Section) received Halifax County Ash Monofill (NC Permit 42-04-INDUS-1994), Conceptual Filling and Intermediate Cover Plan, prepared for Halifax County, prepared by Smith-Gardner. On October 22, 2015, the Solid Waste Section concurred with the plan. The northern slope of the landfill has had soil cover placed, and been graded and seeded per the Cover Plan. The western slope has had soil cover placed, and been graded and mulch as of the December 1, 2016 inspection. Vegetative cover should be established to prevent erosion. (identified as Sequence No. 3B in the Cover Plan). Other slopes have been regraded to reduce erosion. Continue to place intermediate cover on all slopes in accordance with the Cover Plan. Unresolved. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 2 15A NCAC 13B .0203(d) states “By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.” Ops Plan 2.5.6.2 states “unless suitable vegetation can be established on the surface of the ash a 12-inch layer of soil cover should be placed over the ash on all outer side slopes. This intermediate cover should be seeded immediately and graded such that all precipitation run-off is channeled to the surface water systems.” The facility is in violation of the above rule in that it failed to prevent the erosion of the side slopes by not providing soil cover and/or permanent vegetation as noted in Ops Plan 2.5.6.2. The northern slope of the landfill has had soil cover placed, and been graded and seeded per the Cover Plan. The western slope has had soil cover placed, and been graded and mulched as of the December 1, 2016 inspection. Vegetative cover has been established to prevent erosion. (identified as Sequence No. 3B in the Cover Plan. Other slopes have been regraded to reduce erosion. Continue to place intermediate cover on all slopes in accordance with the Cover Plan. Unresolved. OBSERVED VIOLATIONS: None. ADDITIONAL COMMENTS The coal ash landfill is one of several units located at the facility owned by Halifax County. The other units include a construction and demolition landfill, a municipal solid waste (MSW) transfer station, and a closed unlined MSW landfill. The Permit to Operate expired March 27, 2017. A request to the Section for permit review has been submitted and is pending review. 1. The coal ash landfill is permitted to receive only coal combustion by-products in accordance with the approved plan. Municipal solid waste, construction and demolition debris waste, land clearing and inert debris, hazardous waste, special waste, and liquid waste are prohibited from disposal in the coal ash landfill. 2. The facility operator must complete an approved operator training course in compliance with G.S. 130A-309.25. The following facility staff are Certified Landfill Operations Specialists: Edgar Stanfield, LF-2001362, expires June 13, 2019 Randy Pike, LF-2015025, expires May 20, 2018 Trenton Smith, LF-2017041, expires April 11, 2020 3. The landfill is permitted to receive waste only from the coal-fired power plant in Weldon, NC (which is currently owned by the Westmoreland Coal Company). The Westmoreland plant in Weldon is not currently operating thus ash disposal needs are less. The amount of coal ash being brought to the industrial landfill has fallen off significantly since the landfill was first permitted. According to the Facility Annual Report for 7/1/16-6/30/17 approximately 5,240.60 tons of ash were disposed in the monofill during the previous year. No waste was received during March, May or June 2017. 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 3 4. Groundwater, surface water, basin effluent, and stream sediment locations are sampled semi-annually. The last sampling events occurred on August 10, 2016 and February 14, 2017. Results from these events were reviewed during the inspection. Sampling results were consistent with previous events; no concerns were noted. 5. Repairs to monitoring points with previously noted concerns were discussed and noted during the inspection. Correction have been made as noted below: 4204-INDUS-1994 Monitoring Well ID Well Tag Concrete Pad Comments Groundwater Monitoring Wells MW-8 Yes Yes Needs lock MW-9 Yes Yes Locked, pad good MW-10 Yes Yes Locked, pad good MW-11 Yes Yes Locked, pad good MW-12 Yes Yes Needs lock, well cap on ground MW-17 Yes Yes Locked, pad good Surface Water Locations SW-3 NA NA Sign has been posted at sample location Basin 1 NA NA Sign has been posted at sample location Sediment Basin Sample Locations SS-1 NA NA Sign has been posted at sample location SS-2 NA NA Sign has been posted at sample location 6. No unpermitted waste was observed in the landfill during the inspection. 7. Ash is currently being placed in Cells 1 and 2. Spreading and compaction of the ash is performed with a D6 bulldozer. 8. Edge-of-waste markers were in place and being maintained. 9. Dust control is performed consistent with the facility’s Fugitive Dust Control Plan. During periods without significant precipitation, facility staff should be extra diligent in monitoring and addressing dusting on and around the working face. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 4 10. On October 20, 2015 the Division of Waste Management, Solid Waste Section (Section) received Halifax County Ash Monofill (NC Permit 42-04-INDUS-1994), Conceptual Filling and Intermediate Cover Plan, prepared for Halifax County, prepared by Smith-Gardner. On October 22, 2015, the Solid Waste Section concurred with the plan. The northern slope of the landfill has had soil cover placed, and been graded and seeded per the plan. Intermediate cover has been placed on the western slope (identified as Sequence No. 3B in the Cover Plan) and good vegetative cover has been established. The eastern and southern slopes have been regraded to reduce erosion however erosion continues to occur on these slopes during heavy rainfall. Continue to place intermediate cover on all slopes in accordance with the Cover Plan. Southern slope 11. As a reminder, per Permit to Operate, Condition # 59 “Ash which has been placed to final elevations around the perimeter of the facility must be covered with a minimum of 12 inches of soil. Final cover and seeding must be implemented within 30 days of an area reaching final grade.” Additionally, per 15A NCAC 13B .0505(3)(c) “After final termination of disposal operations at the site or a major part thereof, or upon revocation of a permit, the area shall be covered with at least two feet of suitable compacted earth.” 12. The sediment basin appeared to be functioning as designed at the time of the inspection. Continue to monitor the inlet to the basin for any signs of ash migration. Please contact me if you have any questions or concerns regarding this inspection report. _ Phone: 919-707-8284 Shawn McKee Environmental Senior Specialist Regional Representative Sent on: August 18, 2017 Email: X Hand delivery US Mail Certified No. [ _] Copies: Ellen Lorscheider, Section Chief, Solid Waste Section Ed Mussler, Permitting Branch Head, Solid Waste Section Jason Watkins, Field Operations Branch Head, Solid Waste Section Elizabeth Werner, Permitting Hydrogeologist, Solid Waste Section Shannon Aufman, Permitting Engineer, Solid Waste Section