CCB0008_CoverLetter_20200123

North Carolina Department of Environmental Quality | Division of Waste Management
217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200

January 23, 2020

Mr. George G. Irving Jr.
Mrs. Rinda Prince Irving
160 Greenhill Rd, NE
Winnabow, NC 28479

SUBJECT: Structural Fill Inspection and Maintenance Reminder
Irving Farm Road
Coal Combustion By-Products Structural Fill CCB0008
Brunswick County

Dear Mr. and Mrs. Irving:

On November 21, 2019, Liz Patterson and Ben Jackson, representing the Solid Waste Section
(Section), inspected property containing the closed Irving Farm Road CCB0008 located at 160
Greenhill Rd. NE Winnabow, NC 28479(N 34.14810 W -78.10012) in Brunswick County. The
structural fill on this property was constructed under the rules codified in 15A NCAC 13B
Section .1700. This land based application of coal combustion by-product will be utilized to elevate
a section of land for use as a farm access roadway to be constructed parallel to the Brunswick Electric
transmission lines. (Although the power poles and transmission lines extend across the Irving
property, Brunswick Electric does not possess a deeded right-of-way or easement. Simply, Brunswick
Electric is granted access to the property by the landowner). Parcel # 0840000502. Brunswick Co.;
Book 3717 Page 1367.

Current use of structural fill is same as before, structural fill was used to elevate a section of land for
use as a farm access roadway. Did not appear to be any ash migration issues at time of inspection.

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.”

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
North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646
919.707.8200
Irving Farm Road
Inspection/Maintenance Letter
Page 2 of 2
January 23, 2020

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
and is now well vegetated..

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 me at (910)
796-7405 or e-mail [e-mail].

Sincerely,

Liz Patterson
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
Jason Watkins, Field Operations Branch Head