CCB0037_CORR_20191120

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
\RtQ�N°E%
NORTH CAROLINA
Environmental Quality
November 20, 2019
Sentvia email: [e-mail]
Mr. Max Hopkins, Senior Staff Engineer
R. J. Reynolds Tobacco Company
P. 0. Box 2959
Winston-Salem, NC 27102
SUBJECT: Structural Fill Inspection and Maintenance Reminder
Tobaccoville Project
Coal Combustion By -Products Structural Fill CCB0037
Forsyth County
Dear Mr. Hopkins:
On November 12, 2019, Susan Heim and Larry Frost, representing the Solid Waste Section (Section),
inspected property containing the closed Tobaccoville Project, CCB0037 in Forsyth County. The
structural fill on this property was constructed under the rules codified in 15A NCAC 13B
Section .1700. Records indicate that the fill was constructed of 100% coal ash between September
1, 2001 and January 31, 2005. The original notification estimated 176,000 cubic yards of ash would
be landfilled at the site. However, final closure documents state that the site was closed after
approximately 50,000 cubic yards were landfilled.
No problems were found at the site. The structural fill was observed to be stable, with a well -
established and well -maintained vegetative cover. No evidence of erosion was found, and no exposed
ash was visible. The side slope, which runs along the eastern edge of the fill area, had been
constructed with a very gentle grade to prevent erosion and the infiltration of precipitation into the
fill area. The structural fill had originally been established with plans to develop the site into a new
manufacturing plant. These plans were cancelled, and the site remains undeveloped.
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
the potential for harmful release of constituents of coal combustion by-products to the environment
or create a nuisance to the public."
NORTH CAROL INAD_E QWA)
Oep,oi—t of E,okoem , I OuI
North Carolina Department of Environmental Quality I Division of Waste Management
Winston-Salem Regional Office 1 450 W. Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

November 20, 2019
Tobaccoville Project
CCB0037
Page 2 of 2
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
earthen material which supports a well -established vegetative cover. This cap system appears to
meet the requirements of .1705(j).
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 (336)
776-9672 or via e-mail at susan.heim(@ncdenr.gov.
Sincerely,
DN, .-:i , ev -SBeim
S �n=s-F,,leiOp—t iltl wane
Section, ou=Field Operations
Br it
ssan — .Ueim(mn<tlenr .gov.
c-US
Date'. 2019. 11.2013.38: 18-05'00'
Susan Heim
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
copies: Ed Mussler, Section Chief - Solid Waste Section
Sarah Rice, Environmental Program Consultant - Solid Waste Section
Larry Frost, Permit Engineer - Solid Waste Section
Jason Watkins, Field Operations Branch Head - Solid Waste Section
NORTH ARa1 N D_E Q�/WAj
Dep,dm tof Ep wvnrne IOu,lity
North Carolina Department of Environmental Quality I Division of Waste Management
Winston-Salem Regional Office 1 450 W. Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800