CCB012_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

February 11, 2020

Mr. and Mrs. Phelps
862 Byrdville Freeman Road
Delco, North Carolina 28436

SUBJECT: Structural Fill Inspection and Maintenance Reminder
Small Aircraft Landing Strip
Coal Combustion By-Products Structural Fill CCB0012
Columbus County

Dear Mr. and Mrs. Phelps :

On November 21, 2019, Liz Patterson and Ben Jackson, representing the Solid Waste Section
(Section), inspected property containing the closed Small Aircraft Landing Strip, CCB0012 located
at 862 Byrdville Freeman Road Delco, North Carolina 28436 in Columbus County. The structural
fill on this property was constructed under the rules codified in 15A NCAC 13B Section .1700. Site
located in Columbus County on Byrdville Freeman Road. The property with the CCB is Nicholas J.
Phelps and Brooke P. Phelps . The CCB was generated by Cogentrix Eastern Carolina Corp plants
located in Lumberton and Elizabethtown, NC. An estimated 9,500 cy of CCB was to be used for this
project. The CCB was used to create a landing strip for small aircraft. The CCB was mixed with a
cementitious binder during the construction of the landing strip according to Mr. Stan Grice.
Recordation is not required. There was no evidence of erosion and the site was heavily vegetated.
Doesn’t appear to be any ash migration issues at the time of this audit. The project was completed
in July 1995.

Site was well-vegetated and no apparent ash migration noted.

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
be covered with a minimum of 12 inches compacted earth, and an additional surface six inches of soil
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
CCB0012 Small Aircraft Landing Strip
Inspection/Maintenance Letter
Page 2 of 2
February 11, 2020

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 a soil
cap.

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