3405_INSP_20210323

NORTH CAROLINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: Forsyth
MSWLF
PERMIT NO.: 3405-INDUS-1986
Closed
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: March 23, 2021 Date of Last Inspection: January 16, 2018
FACILITY NAME AND ADDRESS:
R. J. Reynolds Industrial Landfill — Rural Hall
Edwards Road
Rural Hall, NC
GPS COORDINATES (decimal degrees): Lat.: 36.248567' Long.:-80.280041'
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Max E. Hopkins, Senior Staff Engineer
Telephone: [phone]
Email address: hopkinmlkrirt.com
FACILITY CONTACT ADDRESS:
R. J. Reynolds Tobacco Company
401 North Main Street
Winston-Salem, NC 27101
PARTICIPANTS:
Max Hopkins, Senior Staff Engineer — R. J. Reynolds Tobacco Company
Dave Wasiela — ERM NC, Inc.
Susan Heim, Environmental Senior Specialist — Solid Waste Section
STATUS OF PERMIT:
Closed
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
N/A
OBSERVED VIOLATIONS:
None
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.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
ADDITIONAL COMMENTS:
1. All photos included in this report were taken by Susan Heim on March 23, 2021 during the inspection.
2. The facility is a closed, unlined industrial landfill that ceased operations on December 31, 2002. The facility had
been used solely to dispose of fly ash from the R. J. Reynolds Tobacco Company's manufacturing operations.
3. In 2012, the facility received approval for and completed major modifications to the landfill, in an effort to
remediate surface water and groundwater contamination. The project included redesign of the fill area to
eliminate the large, flat top that had allowed surface water to pond and penetrate the landfill cap and flow
through the waste. The new design created slopes that permit surface water to sheet flow off the landfill without
coming into contact with waste. In addition, a geosynthetic cap was installed over the entire landfill, which
directs surface water to the new drainage system that parallels the toe of the landfill and discharges runoff into
three sediment ponds around the perimeter of the facility.
4. In February 2020, a sediment boil was discovered just above the sediment pond on the southeast slope of the
closed landfill. Facility staff notified Jaclynne Drummond, Solid Waste Section Hydrogeologist, of the issue,
stating that they had conducted an inspection of the landfill following a 5.6" rainfall. The report stated that
evidence of a recently active boil was observed immediately downgradient and beyond the limits of waste and
anchor trench drain near sediment trap ST-1. Staff reported dark -colored sediment suspected to be coal ash had
migrated from the approximately 2" diameter hole on the surface to ST-1, approximately 30' downgradient; no
evidence of this boil and sediment deposit had been observed during the previous quarterly inspection of the
facility on December 12, 2019. Since the initial report, facility staff have installed silt fence and wattles to
capture and containerize any sediment that is emitted from the boil and properly dispose of it. Mr. Hopkins
estimated that approximately 10 cubic feet of dark -colored sediment had been collected from the containment
measures between the discovery of the boil on February 10 and the initial summary report dated April 16, 2020.
In addition, four temporary piezometers were installed near the boil to monitor the depth and location of water
migrating in the shallow subsurface near the boil. Two surface water sampling events were conducted on
February 17 and 24, 2020. Surface water monitoring data indicated no changes in water quality related to the
landfill had occurred.
5. Since the February 10, 2020 observations, facility staff have continued to monitor the boil and to attempt to
locate its source. The containment measures installed near the boil have proven effective in preventing the
migration of additional sediment to the nearby pond, and Mr. Hopkins stated that only minimal amounts of
sediment had been found since April 2020. He added that the activity of the boil seems to have decreased over
time.
6. Monthly reports are submitted to Ms. Drummond that summarize monitoring results, and facility staff have
worked with her to brainstorm methods for investigating the source of the boil. During this inspection, Mr.
Hopkins explained that the facility is contracting with a company to perform leak testing as another method for
investigating the source of the sediment boil. He added that the testing would take place this spring.
7. Semi-annual groundwater monitoring takes place at the facility as required. The four most recent monitoring
events were conducted March 18-19, 2019, September 3-4, 2019, March 31 — April 2, 2020, and September 23-
24, 2020. These reports were reviewed online and verified.
Field Inspection:
8. The facility is accessed from a right-of-way easement across an adjoining property with frontage on Edwards
Road. The roadway entrance is secured by fencing and a locked gate that prevents unauthorized access. A
locking cable strung between two bollards is situated inside the entry gate farther along the access roadway and
serves as a secondary barrier.
9. The facility access roadway is of all-weather construction and maintained in good condition.
10. The entire site was observed to be well -maintained. Mr. Hopkins stated that the landfill is mown at least twice a
year, but more frequently if necessary.
11. The disposal boundary is identified by a series of white PVC markers that are located at regular intervals around
the entire perimeter of the landfill. Edge -of -waste markers with a blue top indicate the location of drainage
outlets, and several of these were noted during the inspection.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
12. Two monitoring wells were observed during the inspection and were found to be properly tagged and locked, as
required.
13. Conditions at the landfill were wet. As a result of the cumulative effect of the heavy rainfall events that had
been recurring over the past year, the landfill cap was saturated. However, the vegetative cover was observed to
be thick and intact, with no erosion evident.
14. The southeastern slope of the landfill is constructed in a series of terraces that lead down to sediment trap ST-1.
Mud was visible on some of the terraces; however, no standing water was observed, and the vegetative cover
was undamaged.
15. Drainage ditches were found to be clear and functional.
16. The site of the sediment boil was inspected and found to be dry. Mr. Wasiela pointed out the boil itself, which
appeared to be approximately 1.5" in diameter. He added that activity at the boil had decreased since it was
discovered in February 2020, and the sediment flow has become minimal.
17. Mr. Wasiela stated that the location of the boil had moved after the area had been excavated in an effort to
determine the source of the boil. After repairs had been completed, the boil popped up in a new spot a short
distance to the southeast of the original location.
18. A small amount of sediment was noted at the silt fence that had been installed downslope from the boil. No
dark -colored soil was visible in the accumulated sediment.
19. The sediment pond, ST-1, located below the silt fence, appeared to be functioning properly with capacity
available to accommodate additional rainfall events.
20. Several yards upslope and east of the boil, a small stream of what appeared to be surface water was flowing out
of the slope itself. No discoloration was noted in the water, and no vegetation had been damaged in the
surrounding area. In a phone conversation following the inspection, Ms. Drummond stated that this water flow
might be the result of the oversaturation of the landfill cap or might somehow be related to the sediment boil.
She added that she would await results from the leak testing to find out if the source of these issues is revealed
and, if so, what corrective actions would be indicated.
A view of the southeastern slope of the landfill. Some mud is noticeable on one of the terraces, but vegetative cover is
intact, and the landfill cap is in good condition.
Page 3 of 5

NORTH CAROLINAD_E Q��
OepeNnenf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A close-up view of the sediment boil. The
opening is approximately 1.5" in
diameter.
A view of the
sediment boil area.
The boil itself is
located just above
the silt fence seen at
left with the
sediment trap below
it (right). The area
of the surface water
flow can be seen in
the lower right
corner, marked with
light green algae.
Page 4 of 5

NORTH CAROLINAD_E Q��
OepeNnenf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A close-up view of the surface water flowing out of the slope east of the boil. The flow was approximately 3"
wide and appeared clear.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan
Heim
DN: cn=Susan Heim, o=Solid
6 ti Waste Section, ou=Field
Operations Branch,
email=susan.heim@ncdenr.g
ov, c=US
Date: 2021.03.29 15:11:56
-04'00'
Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: March 29, 2021 to
Email
Hand delivery
US Mail
Certified No. [ ]
Max Hopkins.
Copies: Deb Aja, Western District Supervisor — Solid Waste Section
Jaclynne Drummond, Hydrogeologist — Solid Waste Section
Page 5 of 5