3606-20121217 RSPNS to NOV

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GASTON COUNTY Department of Public Works
`¢ J SOLID WASTE AND RECYCLING DIVISION
X g46 3155 Philadelphia Church Road, Dallas, NC 28034 Telephone [phone]§T 4 ffMD
December 17, 2012
Mr. Bill Wagner
Environmental Senior Specialist
NCDENR — Asheville Regional Office
Solid Waste Section
2090 U.S. Highway 70
Swannanoa, NC 28778
RE: Response and Action Plan to Address Notice of Violation
Compliance Inspection Report
Gaston County Hardin Landfill — Facility # 36-06
Gaston County, North Carolina
Dear Mr. Wagner:
DEC 19 2012
SOLID WASTE SECTION
ASiiEVILLE REGIONAL OFFICE
The County would like to offer additional clarification to certain matters relating to the Notice of
Violations (NOV) issued for the Gaston County Hardin Landfill Facility (Permit No. 36-06)
stemming from compliance inspections conducted by the Solid Waste Section (SWS) on
October 11, 2012 and October 15, 2012.
At the time of the inspection, the County had already initiated measures to stabilize landfill side
slopes and other disturbed areas as a matter of routine landfill operations. In fact, the pictures
included in the subject NOVs clearly show that some of the side -slope areas cited had been
recently hydroseeded. However, a number of rain events occurred after seeding operations and
prior to germination of the seed, which adversely impacted efforts to re-establish vegetation.
The County wants to make the point that an aggressive erosion and sediment control plan is
being pursued, but with poor native soils and periods of hot and dry weather, maintenance of
vegetative cover is an on -going process at the landfill. We assume that this is the case for most
landfill operations.
The regulations cited in the NOVs are rather broad in terms of actually defining excessive
erosion and adequate sediment control measures from a compliance standpoint. The
prevention of silt leaving the footprint of an MSWLF or C&DLF unit is virtually impossible during
a significant storm event, which to our understanding is why there are site erosion and sediment
control measures in place. These measures backstop any erosion from a waste unit side slope
and prevent silt from leaving the site. As was observed at the time of the inspections, these
measures (drainage ditches and sediment control ponds) functioned as designed and prevented
any silt from leaving the MSWLF facility even though some erosion of side slopes had occurred.
Missiou Statement
Gaston County seeks to be a mmig the finest counties in North Carolina. /t will provide effective, efficient and affordable
services leading to a safe, secure mud healthy community, an environment for economic growth, mad promote a favorable
duality of life.
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The County would like to request additional guidance and direction from the SWS regarding
what is considered excessive erosion from the footprint of a waste unit. The erosion that was
cited did not result in the exposure of buried waste or result in silt leaving the facility site
boundaries.
The County has completed mitigation measures to address the erosion and sediment control
violation noted, which included the following actions pursued in consultation with Land Quality
recommendation regarding seed and fertilizer applications.
CORRECTIVE ACTIONS TAKEN TO ADDRESS EROSION NOVs
Week of October 8
Reseeded the southern and western facing slopes of C&D.
• Regraded area behind Unit I.
Week of October 15
• A heavy rain event occurred on Monday requiring a complete rework
of those areas completed during previous week.
• Began reseeding bottom of slope on back of Unit I.
• Reseeding from first step down on southern facing slope of Unit It.
Week of October 22
Cleaned ditches around pump station and put in check dams.
Reseeded work once grading was complete.
• Reworked back on Unit I and prepared middle step for reseeding.
• Reseeded and mulched back sections of Unit I.
Week of November 5
Purchased lime and spread on C&D slopes, Unit I and II.
• Reseeded middle step on Unit I.
Week of November 19
Completed reseeding and additional over -seeding on back of Unit I.
• Reworked ditch on inside of road around Pump Station No.1. Checked
grades to ensure appropriate fall.
• Over -seeded and placed additional fertilizer on north side of C&D and
covered with mulch.
• Started installation of slope drains on Unit I.
Week of November 26
Continued slope drain installation on back of Unit I.
• Placed additional mulch on slopes to stabilize MSW and C&D. Rented
straw blower.
• Began watering slopes that have been reseeded during last two
months because of no rain. Used hydroseeder to water slopes.
Week of December 3
• Finished grading of Unit I top step.
• Installed final 2 lengths of slope drain.
• Continued reseeding and finish work on the back of Unit I and C&D.
• Watered slopes that have reseeded.
Week of December 10, 2012
All slopes reworked in the last 2 months were over -seeded this week
and remulched.
• Unit I slope drain installation was completed.
CORRECTION ACTION COSTSUMMARY
Seed: $2,994.21
Lime: $1,625.00 (45 tons)
Fertilizer: $1,745.57 (Special blend based on soil sampling)
Straw: $1625.00
Mulch: $1,939.74
Piping: $1,375.00
Mission Statement
Gaston County seeks to be among the finest comities in North Carolina. It will provide effective, efficient and affordable
services leading to a safe, secure and healthy community, an environment for economic growth, and promote a favorable
quality of life.
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The County is currently working with its Engineer to research previous mapping and permitting
documents to confirm C&D waste boundaries, and to develop a staking plan that does not
violate the integrity of the earth cap of the piggy -backed MSW cell. This work will be completed
within 30 days.
Please advise if any further action or documentation is required by the County to achieve
compliance and address the referenced NOV.
If you have any questions regarding this matter, please contact me at
marcie.smithna co aaston nc us or 704-922-0267.
Sincerely,
�-/1 -svclq�-
Marcie A. Smith
Solid Waste and Recycling Administrator
cc: Ray Maxwell, Gaston County
Robert C. Sallach, PE, CHA
Larry Frost, NCDENR
Mission Statement
Gaston County seeks to be among theftnest counties in North Carolina. It will provide effective, efficient and affordable
services leading to a safe, secure and healthy community, all environment for economic growtb, and promote a favorable
quality of life.
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