0603_AveryCo_CDLF_CAP_FID1389563_20200207

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
SMITH{ GARDNER
ADORESS TEL WEB
14 N. Boylan Avenue, Raleigh NC 27603 919.828.0577 www.smithgardnerinc.com
ENGINEERS
February 7, 2020
Mr. Kris Riddle
Environmental Senior Specialist
Division of Waste Management, NC DEQ
2090 US Highway 70
Swannanoa, NC 28778
Garty Ss idWste Nbiagemit.•
1• li
1ngJ1s,NYthCardina
Dear Kris:
On behalf of Avery County Solid Waste Department (County), Smith Gardner, Inc. (S+G) has
prepared this Corrective Action Plan in response to Observed Volations received January 27,
2020 (Attachment 1), documenting the Site Inspection performed on January 16, 2020. Please
find each violation or comment in bold followed byour response in italics.
Observed Violations
1. 15A NCAC 13B .0542(f)(2) partially states, "areas which will not have additional
wastes placed on them for three months or more, but where final termination of
disposal operations has not occurred, must be covered and stabilized with vegetative
ground cover or other stabilizing material."
To achieve compliance, within seven (7) days of receipt of this Facility Compliance
Inspection Report, Avery County Solid Waste Management Facility Permit No. 06-03
must cover the eastern and southern slopes of C&D landfill Phase 3, Cell 2.
Additionally, within sixty (60) days of receipt of this Facility Compliance Inspection
Report, Avery County must stabilize the eastern and southern slopes of C&D landfill
Phase 3, Cell 2 with vegetative ground cover or other stabilizing material.
The Countyplaced additional fill on the eastern and southern slopes following
inspection byDEQ and notified DEQof this work January29, 2020 through emailed
pictures. The County will further place cover soil as necessary. The County will
attempt to stabilize the slope through hydroseeding beginning in April, to coincide
with the growing season.
2. 15A NCAC 13B .0542(k)(2) states, "Adequate sediment control measures consisting of
vegetative cover, materials, structures or devices must be utilized to prevent
excessive on -site erosion of the C&DLF facility or unit".

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
Mr. Kris Riddle
February 7, 2020
Page 2 of 3
To achieve compliance, within sixty (60) days of receipt of this Facility Compl iance
Inspection Report, Avery County Solid Waste Management Facility Permit No. 06-03
must utilize adequate sediment control measures to prevent excessive on -site
erosion of the C&DLF facilityor unit.
The County is working to remedy the noted erosion above Sediment Basin 2, but due
to weather and saturated conditions on the slope, work has not progressed. The
county intends to correct issues along the slope above Sediment Basin No. 2, and
revegetate, as weather permits
3. 15A NCAC 02C .108(o) states: "Each non -water supply wel I shal I have permanently
affixed an identification plate. The identification plate shall be constructed of a
durable, waterproof, rustproof metal or other material approved by the Department
as equivalent and shall contain the following information:
i. Well contractor name and certification number;
ii. Date completed;
iii. Total depth of well;
iv. Awarning that the well is not for water supply and that groundwater
may contain hazardous materials;
v. Depth(s) to the top(s) and bottom(s) of the screen(s); and,
vi. The well identification number assigned by the well owner."
To achieve compliance, Avery County Solid Waste Management Facility Permit No.
06-03 must affix a permanent identification plate to the outer steel casing of all
facility monitoring wells as specified in 15A NCAC 02C .0108(o).
This work will be completed by the end of February.
4. Ensure that LFG monitoring of the Scalehouse is conducted during quarterly facility
L FG sam pl i ng events.
Due to the presence of a perennial stream which prevents the migration of landfill
gas from the landfill unit in the direction of the scalehouse, we believe it is
unnecessary to monitor the scalehouse. This stream is shown on Figure 9 of the
LFGWP. if acceptable, a revised LFGMP will be submitted omitting this requirement.
5. Ensure the facility incorporates H2S monitoring into the quarterly LFGsampl ing
events, per the approved LFG Monitoring Plan.
The County will monitor for H2S moving forward.
6. Maintain erosion control measures at the facility as necessary, including: sediment
basins, ditch -lines, rip -rap channels, diversion berms, and vegetative ground cover.
The County acknowledges this comment.

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
Mr. Kris Riddle
February 7, 2020
Page 3 of 3
We appreciate your attention in this matter and are prepared to respond to any questions or
concerns. Should you require clarification, please contact us at [phone] or by email,
bel ow.
Sincerely,
SATUTUER I W-,
EDocuSigned by:
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SB1372167E5F488...
Spencer W. HolIomon, P.
Project Engineer, x134
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spencer�mithgardnerinc.com
Attachment
cc: Eric Foster, Avery County
Allen Gaither, NC DEQ
S�-E DocuSigned by:
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3369FBA008BB445... (r •• •r
Stacey A. Smith, P.E. %4,ety �,�cl�.�`
Senior Engineer, x127 sre„Mil„ ,ozo
stacey@�mithgardnerinc.com

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
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DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
FACILITY COMPLIANCE INSPECTION REPORT
NORTH CAROLI D_EQ��
OepnMiml of Enrlrommenlal Ounl�
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: AVERY
MSWLF
PERMIT NO.: 06-03
Closed
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
X
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: 1/16/2020 Date of Last Inspection: 3/13/2018
FACILITY NAME AND ADDRESS:
Avery County Solid Waste Management Facility
2175 Brushy Creek Road (SR-1011)
Ingalls, NC 27610
GPS COORDINATES: Lat: 35.959872' Long:-81.970638'
FACILITY CONTACT NAME, PHONE NUMBER, & EMAIL:
Name: Eric Foster, Solid Waste Director — Avery County
Telephone: [phone]
Email address: avery.sw(c-r�,averycountync.gov
FACILITY CONTACT ADDRESS:
Avery County Solid Waste Department
P.O. Box 640
Newland, NC 28657
PARTICIPANTS:
Kris Riddle, Environmental Senior Specialist, Solid Waste Section (Section)
Robert Banner, Landfill Operator, Avery County Solid Waste Department
STATUS OF PERMIT:
Active. Permit No. 06-03 (Doc ID 1235393) issued on August 29, 2018, includes:
Permit to Construct: Avery County Construction & Demolition (C&D) Landfill Phase 3, Cell 3;
Permit to Operate: Avery County C&D Landfill Phase 3, Cells 1 & 2;
Avery County Transfer Station;
Permit for Closure: Avery County C&D Landfill Phases 1 & 2.
PURPOSE OF SITE VISIT:
Comprehensive Facility Inspection.
STATUS OF PAST NOTED VIOLATIONS:
None.
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .0542(f)(2) partially states, "areas which will not have additional wastes placed on them
for three months or more, but where final termination of disposal operations has not occurred, must be
covered and stabilized with vegetative ground cover or other stabilizing material".
During this inspection, it was observed that inadequate cover material had been placed along the eastern and southern
slopes of the C&D landfill Phase 3, Cell 2 (photo #1). Some exposed C&D wastes were observed along these slopes of the
facility. Post -inspection, the Section contacted Avery County Solid Waste Director, Mr. Eric Foster, who stated the
facility does not plan to place additional wastes on these slopes at this time. Mr. Foster also stated an adequate amount of
Page 1 of 6

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
cover was placed on these slopes previously, but due to adverse weather conditions, stabilization efforts had been delayed.
Mr. Foster further stated that since the date of this inspection, adequate cover material (12 inches of soil) had been placed
on these slopes and that stabilization efforts would occur as soon as possible.
To achieve compliance, within seven (7) days of receipt of this Facility Compliance Inspection Report, Avery
County Solid Waste Management Facility Permit No. 06-03 must cover the eastern and southern slopes of C&D
landfill Phase 3, Cell 2. Additionally, within sixty (60) days of receipt of this Facility Compliance Inspection
Report, Avery County must stabilize the eastern and southern slopes of C&D landfill Phase 3, Cell 2 with
vegetative ground cover or other stabilizing material.
1. Southern view of eastern slope of Phase 3, Cell 2. Note:
coverage and stabilization appear inadequate.
2. 15A NCAC 13B .0542(k)(2) states, "Adequate sediment control measures consisting of vegetative cover,
materials, structures or devices must be utilized to prevent excessive on -site erosion of the C&DLF
facility or unit'.
During this inspection, areas of excessive on -site erosion were observed along the eastern side of the facility above
Sediment Basins #2 and #3 (photos #2 & #3). Since the previous inspection, the slope above Sediment Basin #2 has
been graded/cut, which appears to have caused a slope failure in this area of the facility. Erosion gullies were observed
above Sediment Basin #2. Sediment Basins #2 and #3 appeared to have received the sediment from the slope failure. No
sediment was observed off the facility property.
To achieve compliance, within sixty (60) days of receipt of this Facility Compliance Inspection Report, Avery
County Solid Waste Management Facility Permit No. 06-03 must utilize adequate sediment control measures to
prevent excessive on -site erosion of the C&DLF facility or unit.
Page 2 of 6

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
2. Southern view of erosion above Sediment Basin 3. Northern view of Sediment Basin #2 (in
#2 at the facility. foreground) and the cut slope above Sediment Basin
#2 (in background).
3. 15A NCAC 02C .0108(o) states: "Each non -water supply well shall have permanently affixed an identification
plate. The identification plate shall be constructed of a durable, waterproof, rustproof metal or other material
approved by the Department as equivalent and shall contain the following information:
(1) well contractor name and certification number;
(2) date well completed;
(3) total depth of well;
(4) a warning that the well is not for water supply and that the groundwater may contain hazardous
materials;
(5) depth(s) to the top(s) and bottom(s) of the screen(s); and
(6) the well identification number or name assigned by the well owner."
The site -wide Groundwater monitoring network includes four monitoring well locations that serve to monitor both the active
and closed C&D facilities on -site. Additionally, the site -wide landfill gas (LFG) monitoring network includes four
monitoring well locations that serve to monitor both the active and closed C&D facilities on -site. As discussed with facility
personnel during this inspection, it was observed that some identification plates were maintained on environmental
monitoring wells at the facility, but identification plates were not maintained on all groundwater and LFG monitoring wells
at the site (photos #4 & #5). See Tables #1 & #2 below for additional information. Post -inspection, Avery County contacted
the Section to state the facility had informed the site's Proj ect Engineer of the necessity to gain compliance with 15A NCAC
02C .0108(o).
Table 1: Groundwater Monitoring Wells -
Groundwater Monitoring Well #IA
Well labeled. Identification Plate installed but contained no
information. Well locked.
Groundwater Monitoring Well #2S
Well labeled. Identification Plate maintained. Well locked.
Groundwater Monitoring Well #3S
Well labeled. Identification Plate maintained. Well locked.
Groundwater Monitoring Well #4S
Well labeled. Identification Plate not installed. Well locked.
Table 2: Landfill Gas Monitoring Wells -
Landfill Gas Well #GP-1
Well labeled. Identification Plate installed but contained no information.
Well locked.
Landfill Gas Well #GP-2
Well labeled. Identification Plate installed but contained no information.
Well locked.
Landfill Gas Well #GP-3
Well labeled. Identification Plate not installed. Well locked.
Landfill Gas Well #GP-4
Well labeled. Identification Plate installed but contained no information.
Well locked.
Page 3 of 6

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
FACILITY COMPLIANCE INSPECTION REPORT
N-THCA­ IND_EQ��
Department pl EnvironmenW10uali�
Division of Waste Management
Solid Waste Section
To achieve compliance, Avery County Solid Waste Management Facility Permit No. 06-03 must affix a permanent
identification plate to the outer steel casing of all facility monitoring wells as specified in 15A NCAC 02C .0108(o).
* For additional information, please see the Section's March 23, 2017 Memorandum titled "Permanent and Temporary
Groundwater and Landfill Gas Monitoring Wells, Piezometers, and Probes", which can be located at the following direct
document link:
htlps:Hfiles.nc. gov/ncdeq/Waste%20Management/DWM/S W/Field%200perations/Environmental%2OMonitoring/MW_
Maint Requirements.pdf
VJARPaNG
GROUN_ LATER
MONITORING WELL
CUSTOMER--
GTY-
.� GIST ITAP ary NO.o
-
s
"\ r
4. Groundwater Monitoring Well #IA. Note:
well labeled and Identification Plate installed but
plate contained no information.
5. LFG Monitoring Well #GP-3. Note: well
labeled but no permanent Identification Plate
containing well information is installed.
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.
ADDITIONAL COMMENTS
1. On -site January 16, 2020, to inspect the active C&D landfill unit, observe facility environmental monitoring wells,
and review facility records/certifications. Mr. Robert Banner, facility Landfill Operator, and Mr. Kris Riddle, Section,
participated in the inspection.
2. Post -inspection, the Section contacted Eric Foster, Avery County Solid Waste Director, on January 17t'', January 23',
and January 24t' to discuss facility operations and records.
The following comments were noted/observed during this inspection:
3. Access was controlled at the facility and signage was displayed at the facility entrance.
Page 4 of 6

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
4. The facility's current operating hours are: Monday — Friday: 8:00 a.m. — 4:30 p.m.; and
Saturday: 9:00 a.m. — 1:00 p.m.
C&D LANDFILL UNIT:
Active C&D Landfill Phase 3-
Records/Certifications-
5. The Permit to Operate (PTO), Updated Operations Plan (FID 1234681), and all necessary records were available for
review.
6. Staff Certifications:
Name
Certification
Expiration Date
Eric Foster
Manager of Landfill Operations
6/2022
Robert Banner
Landfill Operations Specialist
11/2022
7. Per C&D landfill records, the facility accepted on average approximately 7 tons of waste per day for the month of
December 2019. Waste tonnage records from January 2019 through December 2019 were reviewed, appeared complete,
and no issues were noted.
8. Waste screening records for the active C&D landfill Phase 3 were reviewed from January 15, 2019, through January
16, 2020. Waste screening records appeared to be maintained. Per the approved Operations Plan (FID 1234681) Section
2.4.1, continue efforts to ensure that "at least one vehicle per week, but not less than 1% by weight of the waste stream
entering the facility (based on the previous week's total) will be randomly selected by inspection personnel" and that all
unacceptable waste is documented and disposed of properly.
9. The two most recent groundwater and surface water sampling monitoring reports for the facility dated January 2,
2020, (for Fall 2019 sampling event) and June 28, 2019, (for Spring 2019 sampling event) were available for review. As
required, continue to monitor all groundwater and surface water sampling locations at the facility as required and submit
reports to the Section in a timely manner.
10. Methane data (landfill gas) is currently monitored at four on -site wells. The most recent LFG quarterly monitoring
records for the facility, as sampled on 12/26/19, 10/24/19, 6/18/19, and 3/4/19, were reviewed and no methane
detections were recorded in any facility wells. It was observed during the records review that monitoring data for LFG
at the facility Scalehouse was not included on the monitoring reports. The approved Operations Plan (FID 1234681)
Section 4.4 Landfill Gas Control partially states, "All landfill gas monitoring will be performed in compliance with the
Landfill Gas Monitoring Plan". The approved LFG Monitoring Plan (DIN 26148) Section 2.2 Monitoring of Facility
Structures partially states, "The following facility structures will be monitored: Scalehouse". As required, ensure that
LFG monitoring of the Scalehouse is conducted during quarterly facility LFG sampling events. Additionally,
quarterly monitoring for hydrogen sulfide (H2S) in LFG wells is also included in the approved LFG Monitoring Plan.
Section 2.3 Monitoring and Reporting partially states, "During these events the following LFG constituents will be
monitored: methane, hydrogen sulfide, oxygen and carbon". As required, ensure the facility incorporates H2S
monitoring into the quarterly LFG sampling events, per the approved LFG Monitoring Plan.
Operations-
11. Access roads at the facility appeared to be maintained.
12. The working face of the active C&D landfill was inspected and appeared to be compact and maintained. No
unpermitted waste was observed. As discussed on -site, continue the application of weekly soil cover on the active C&D
working face.
Page 5 of 6

DocuSign Envelope ID: 89029CBC-9B93-47F4-8682-E802F4821710
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
13. Continue to maintain waste screening at the active C&D landfill working face. As necessary, segregate from the
working face any unpermitted waste delivered to this unit and properly dispose of the waste.
14. As discussed during this inspection, continue efforts to ensure that any windblown debris is collected and disposed
of daily.
15. Continue to manage and control surface water to ensure it is diverted from all operational and storage areas of this
facility.
16. As discussed on -site, as well as post -inspection, maintain erosion control measures at the facility as necessary,
including: sediment basins, ditch -lines, rip -ray channels, diversion berms, and vegetative ground cover.
17. In reference to Observed Violation #2 of this report, the Section contacted Avery County Solid Waste Director, Mr.
Eric Foster, who stated the grading above Sediment Basin #2 had been conducted as part of the approved Alternative
Final Cover System project (FID 1235915) within part of Phase 3 at the site. Mr. Foster further stated the facility had
contacted the site's Project Engineer to discuss the stabilization of the area(s) above Sediment Basins #2 and #3.
18. Groundwater Monitoring Wells #1A, #2S, #3S, and #4S were observed on -site. Additionally, Surface Water
sampling location area #SW-2 was observed on -site. Access was maintained in these areas. (See Observed Violation #3
in this inspection report for additional information regarding the water quality monitoring well network at the facility.)
19. Methane Monitoring (LFG) wells #GP-1, #GP-2, #GP-3, and #GP-4 were observed on -site. Access was maintained
in these areas. (See Observed Violation #3 in this inspection report for additional information regarding the LFG
monitoring well network at the facility).
20. Continue to maintain all Edge -of -Waste markers on the active C&D landfill phase as necessary.
21. All photographs taken by Kris Riddle on January 16, 2020.
Please contact me if you have any questions or concerns regarding this inspection report.
Phone: [phone]
Kris Riddle, Environmental Senior Specialist
Division of Waste Management, NC DEQ
Regional Representative
Sent to Eric Foster, on
X
Email
Hand delivery
US Mail
Certified No.12
January 27, 2020, via:
E-Copies: Deb Aja, Western District Supervisor — Solid Waste Section
Perry Sugg, Hydrogeologist — Solid Waste Section
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