CCB0060and61_EBGrain_NoViolationCoverLetter_FID1359287_20191010

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
NORTH CAROLINA
Environmental Quality
October 10, 2019
Sent via email to: [e-mail]
Nicholas G Everette, President
E B Grain Company, Inc.
PO Box 158
Battleboro NC 27809
[phone]
SUBJECT: Structural Fill Inspection and Maintenance Reminder
E B Grain Company, Inc and E B Grain Co. Expansion
Coal Combustion By -Products Structural Fill CCB0060 and CCB0061
Nash County
Dear Mr. Everette:
On July 10,2019, Elizabeth Werner, Davy Conners, and Benjamin Jackson, representing the Solid
Waste Section (Section), inspected property containing the closed E B Grain Company, Inc and
Expansion structural fill sites, CCB0060 and CCB0061, located at 7301 and 7101 N US 301, Battleboro,
NC, in Nash County. The structural fill on this property was constructed under the rules codified in
15A NCAC 13B Section .1700. On November 22, 1991 ReUse Technology Inc submitted a request to
the Solid Waste Section to use coal combustion by-products as roadbed material at the EB Grain
facility. Fly ash and bottom ash were proposed to be used for roadway embankments and
foundations and bottom ash was proposed to be used for secondary road overlay. On December 3,
1991 the Solid Waste Section issued a letter to ReUse Technology indicating that the above
referenced project appears to meet the guidelines previously agreed upon for such use. A second
project was submitted on January 6,1992 by ReUse Technology Inc to use approximately 25,000 tons
of CCBs to construct a building pad (Building C). On February 10, 1992, the Section issued a letter
indicating that the second project appears to meet the guidelines previously agreed upon for such
use.
During the inspection, we observed that the road and Building C were in good repair. There were no
visible exposed coal combustion by-products.
Attached is a copy of our site inspection report providing additional information.
Owners of properties containing closed structural fills are responsible for the care and maintenance
of the fill in a manner to ensure protection of the public health and environment. 15A NCAC
13B .1705(a) states in part that structural fills must be "maintained in such a manner as to minimize
D_E
NORTH CAROLINA Q
U
department of En i,e V.tal auality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200

E B Grain Company, Inc and E B Grain Co. Expansion
Inspection/Maintenance Letter
Page 2 of 2
October 10, 2019
the potential for harmful release of constituents of coal combustion by-products to the environment
or create a nuisance to the public."
One of the most effective ways to minimize releases and/or nuisance conditions is to maintain the
approved cap system over the fill in accordance with .1705(j), which states "all structural fills shall
be covered with a minimum of 12 inches compacted earth, and an additional surface six inches of soil
capable of supporting native plant growth." Many of these sites had alternative caps or end uses that
were approved at the time of construction. Currently the cap system at this facility consists of soil,
road and the concrete foundation for Building C.
Section staff may periodically conduct follow-up inspections of this property to determine continued
compliance with the applicable rules. Failure to maintain compliance with the applicable rules could
result in enforcement action. In the interim, if site conditions change due to property usage or if you
observe any changes to the physical conditions of the cap system, please notify the Section
immediately.
Thank you for your cooperation in this matter. If you have any questions, please contact meat (919)
707-8290 or e-mail [e-mail].
Sincerely,
Digitally signed by Davy Conners
DIN: cn=Davy Conners, o=Division of
Waste Management, ou=Solid Waste
Section,
email=[e-mail], c=US
Date: 2019.10.10 11:21:31-04'00'
Davy Conners
Environmental Specialist II
Division of Waste Management - Solid Waste Section
copies: Ed Mussler, Section Chief, Solid Waste Section
Sarah Rice, Environmental Program Consultant, Solid Waste Section
Jason Watkins, Field Operations Branch Head
D_EW
NORTH CAROLINA Q
Aj
ilapaamant Oi EnvironmanGl quality
North Carolina Department of Environmental Quality I Division of Waste Management
217 West Jones Street 11646 Mail Service Center I Raleigh, North Carolina 27699-1646
919.707.8200