44-06, 070109 Audit

AG;j
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: HAYWOOD
MSWLF
PERMIT NO.: 44-06
Closed
EIFIW
white
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
X
DEMO
sDTF
Collection
Monofill
Landfill
Date of Audit: 07/01/09, 09/09/08
FACILITY NAME AND ADDRESS:
Evergreen Packaging Industrial Landfill
State Road 1550
Canton, NC 28716
Date of Last Audit: 07/25/07
GPS COORDINATES: N: 35.548508 E:-82.876149
FACILITY CONTACT NAME AND PHONE NUMBER:
Jim Giauque
[phone]
FACILITY CONTACT ADDRESS:
Jim Giauque
Evergreen Packaging
PO Box 4000
Canton, NC 28716
AUDIT PARTICIPANTS:
Andrea Keller — NCDENR Solid Waste Section
Jim Giauque — Evergreen Packaging/Blue Ridge
Paper Products Inc.
STATUS OF PERMIT:
Active
Section approved (12/14/06) continued use of Landfill No. 6 Area A West until next cell is active (Area D).
Current Operations Manual approved on 02/27/08
PURPOSE OF AUDIT:
Comprehensive
STATUS OF PAST NOTED VIOLATIONS:
None
AREAS OF CONCERN AND COMMENTS:
1. Permit #44-06 — Reviewed Permit and Operations Manual. Landfill is currently active in Area 6A West.
Expect this area to be active until approximately 2/2011.
2. Weather conditions were sunny, dry, mid-80's. Overnight rain —0.39 inches (according to on -site gauge).

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 2
3. The landfill was maintained such that surface water runoff was controlled. No impoundment/ponding of water
was visible over closed/inactive waste disposal areas. Erosion control measures were in place. Area C Lower
was scheduled for mowing (Area C and B lower are proposed for the solar panel project).
4. Caps were maintained on inactive Areas. No erosion issues were noted and vegetation appeared stable.
Landfill access road was gated, but unlocked during operational hours. Sign posted at gate with permit # and
unacceptable wastes. Access roads were well -maintained.
5. Several inactive Areas of the facility are in use as hayfields (crop production). Understanding that this activity
has been on -going for years, please provide documentation (if possible) regarding the Section approval of
this activity.
6. During the audit, the recent Section policy regarding the requirement for waste boundary markers was
discussed. It was communicated that the facility has choice in how they comply with this requirement and that
the Section will be inspecting for visible (marker to marker) and maintained markers.
7. No windblown issues noted. Site accepts fly ash, lime waste, WWTF sludge, wood waste, and cinders. Top of
active area was wet (recent rain) but very little ponding was observed.
8. Fire extinguishing equipment is located in all on -site vehicles. Most recent fire equipment check was on
6/30/09.
9. Leachate generated from the site is piped to the Town of Canton (owned by Evergreen Packaging/Blue Ridge
Paper) Waste Water Treatment Facility (WWTF). Approximately 30,000-35,000 gallons per day are pumped
to the WWTF. The leachate ponds were empty during the inspection (backup system). Evergreen conducts
annual cleanouts of pond/pumps and periodic checks of the leachate pond liner system.
10. The facility accepts asbestos for disposal (generated from internal company activities only). This acceptance is
not noted in either the permit or the Operations Manual. Specifically, the Operations Manual states (section
7.3) that the landfill "is licensed to dispose of wastes which fall into five general categories ... fly ash, lime
waste, WWTF sludge, wood waste, and cinders." It is recommended that the facility update the Operation
Manual (during the next submittal period for the Area D expansion) to reflect all current on -site disposal
and waste management activities.
11. The Areas which historically received asbestos were noted/signed and the active asbestos disposal area was
marked, signed, and controlled in accordance with the Rules.
12. Groundwater monitoring records available and the two previous sampling events were reviewed. Groundwater
monitoring wells will be inspected during future partial inspection.
13. Methane monitoring records were available. The Section recently, in 2008, added landfill gas monitoring
(LFG) to the permit requirements. During review of the records it was noted that the consultant was
monitoring ambient and "in -hole" locations around the perimeter of the property. Data was submitted as
%Volume. It is recommended that the data be recorded (converted/collected) in %LEL (lower explosive limit)
for ease of analysis. Additionally, permanent locations (methane wells) would generate more accurate LFG
readings. It is recommended that a LFG monitoring plan be submitted to the Section for approval, and
that it be added to the next update of the Operation Manual.

FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 3
14. The permit requires adherence to the 15A NCAC 13B .0503(2)(a) Rule which states that the concentration of
explosive gases generated by the site shall not exceed:
W twenty-five percent of the limit for the gases in site structures (excluding gas control or
recovery system components).
Note that the Motor Control Room located by the leachate ponds should be put on the LFG monitoring
plan to verify that the structure meets the above -stated requirements.
15. The Evergreen/Blue Ridge Paper Products Inc. 10-Year Solid Waste Management Plan 3-Year Update was
received at the Asheville Regional Office on June 15, 2009.
16. In general, the facility is well -maintained and operated, the records are in good condition, and the
environmental controls are effectively managed.
Please contact me if you have any questions or concerns regarding this audit report.
Phone: [phone]
Andrea Keller
Environmental Senior Specialist
Regional Representative
Mailed on: 07/08/09 by Hand delivery US Mail Certified No.1I
ec: Mark Poindexter, Field Operations Branch Supervisor
Deb Aja, Western District Supervisor
Donald Herndon, Compliance Officer
Christine Ritter, Permitting Hydrogeologist