1205T-20140804NOV Burke's Rspns 20141010

Burke Countv Gen
P.O. Box 1486 • Morganton, N.C. 28680-1486
110 N. Green Street, Suite A • Morganton, N.C. 28655
828-764-9060 telephone • 828-764-9061 fax
Bill Wagner
NCDENR-Solid Waste Section
2090 US Hwy 70
Swannanoa, NC 28778
10/10/2014
RECEIVED
OCT 1 6 2014
SOLID WASTE SECTION
Mr. Wagner, ASHEVILLE REGIONAL OFFICE
Burke County has received your amended Notice of Violation dated August, 28
2014. In this correspondence you noted:
Section 59.2(c) of Session Law 2013-413 requires containers used to collect and transport solid
waste to "be designed and maintained to be leak -resistant in accordance with industry
standards."
15A NCAC 13B .0203(d) states: "By receiving solid waste at a permitted facility, the
permittee(s) shall be considered to have accepted the conditions of the permit and shall
comply with the conditions of the permit."
• Permit Condition Attachment #1, Part I, #5, of the March 20, 2014 Permit to Operate (DIN
20453) states: "By receiving wastes at this facility the permittee shall be considered to have
accepted the terms and conditions of the permit."
• Permit Condition Attachment #1, Part I, #6, of the March 20, 2014 Permit to Operate (DIN
20453) states, in part, that: "Operations of this solid waste management facility must be in
accordance with the Solid Waste Management Rules, 15A NCAC 13B, Article 9 of the Chapter
130A of the North Carolina General Statutes (NCGS 130A-290, et seq.)..."
• Permit Condition Attachment #3, Part VI, #50 of the March 20, 2014 Permit to Operate (DIN
20453) states, in part that: "All water that comes in contact with solid waste, including vehicle
wash -down water, is leachate and must be captured and properly treated before release to
the environment. (a) The leachate control system, such as floor drains, leachate collection
devices, sanitary sewer connections and leachate storage tanks, must be operational during
facility operations.
15A NCAC 13B .0402 (3) states that: "Water that comes in contact with solid waste will be
contained on -site or properly treated prior to discharge from the site."

Furthermore you advised that Burke County was in violation of permit to operate
#1205T-TRANSFER-1998 when a transfer truck owned by K.R. Drenth, a private
transportation company, and contracted through Republic Services released leachate
into the environment at the Burke County Transfer Station by way of a leak and
potential failure of door seals.
Corrective action was required on the part of Burke County to wit:
A) Submit a plan to the Section for review and approval that details
contingency plans for leaking trailers and which clarifies whether the
loaded transfer trailers are to be staged within transfer bays. Note that as
transfer vehicles are removed from the bay during operational hours,
containment of potential leaks will be required as well and
B) Submit a plan for review and approval to the Section that details a
proposed soil assessment for the region impacted by the leaking transfer
trailer and
C) Upon completion of the corrective action(s) notify (Bill Wagner) at (828)
296-4705.
On September 3, 2014 county staff met with officials from K.R. Drenth at the
Burke County Transfer Station along with officials from Republic Services, who contract
with Burke County for transportation of waste. Potential causes and solutions were
discussed in order to bring the facility back into compliance. K. R. Drenth also received a
notice of violation and were required to provide a response to the Section as well. The
response is attached (see attachment A) and will supplement Burke County's response
plan.
In an attemptto meet requirement A above, countystaff have implemented the
following practices:
1) Transfer station staff will receive training on K.R. Drenth's response plan to
include operation of leachate containment devices provide by K.R. Drenth.
2) Staff will maintain copies of trailer service records on site as provided by
K.R. Drenth and notify same if records are not received on a weekly basis.
3) Trailers will be visually inspected by staff when they exit the transfer bay to
verify that no leaks are present.
4) Should leaks in trailers be detected and K.R. Drenth employees fail to
contain such leaks staff will take action to contain the leak.

5) In order to contain potential leaks staff will maintain on site identifiable
leachate containment devices separate from devices provided by K.R.
Drenth.
Labeled leachate containment barrels of various sizes provided by Burke County
staged with the leachate wagon provided by K.R. Drenth
Emergency spill kit on site at the Transfer Station Office
6) Should a major leak occur in such a manner that provided containment
measures prove ineffective staff will instruct drivers to park trailers in the
transfer station bay in order for leachate to be collected in the on -site
catch basin.

7) Staff will immediately inform K.R. Drenth of defects identified on any of
their vehicles, trailers, or equipment and instruct K.R. Drenth to remove
such vehicles, trailers, or equipment from service until repairs are made.
8) Traffic has been rerouted through the transfer station. Trucks will now
enter the transfer bay from the west and trailers ready for transport will be
staged on the east side of the building. This allows for a natural downhill
slope in order for potential leachate in the trailer to pool toward the front
away from door seals and sludge locks.
Traffic entering transfer bay from the West
Trattic exiting bay and staging on the east side (note the downhill slope)

In regards to requirement B, staff has coordinated with Joyce Engineering to
develop a soil assessment plan for the region impacted by the leachate release.
(See Attachment B)
Burke County feels that with the coordinated efforts of Burke County, K.R. Drenth,
and Republic Services, violations of this type should be minimal in the future if not
eliminated all together. The plan submitted by K.R. Drenth will address the issue of
unauthorized leachate releases into the environment. As a supplement Burke County
will immediately innact the included provisions. Should any part of either plan prove
ineffective the intended redundancies will ensure accidents do not happen again and
will allow time for practices and policies to be amended to ensure compliance with all
state regulations.
The county further understands that this plan and it's attachments are subject to
review and approval by the Solid Waste Section. Please feel free to contact me with any
comments or recommendations should this plan fail to meet your recommendations.
Respectfully Submitted
Brock Hall
Interim Director, Burke County General Services
Cc: Bryan Steen, Burke County Manager
Scott Carpenter, Burke County Deputy County Manager
Wade Goossens, Operations Manager, Republic Services
Scott Barrett, Regional Manager, K.R. Drenth Trucking

Attachment A

KRD Trucking • 20340 Stoney Island • Lynwood, IL 60411 • [phone] • Fax (7OB) 757-3334
August 29, 2014
Mr. Bill Wagner
NCDENR — Solid Waste Section
2090 US Highway 70
Swannanoa, NC 28778
Subject: Notice of Violation
Leachate Release — Transfer Trailer
Location: Burke County Transfer Stations Facility #12-05T
Burke County
Dear Mr. Wagner,
KRD Trucking is in receipt of the NCDENR — NOV dated August 25, 2014.
KRD Trucking understands and accepts the responsibility to comply with the Burke Transfer
Station permit.
Section 59.2(c) Of Session Law 2013-413 requires containers used to collect and transport solid
waste to "be designed and maintained to be leak -resistant in accordance with industry standards."
KRD Trucking does recognize that this is not the first occasion where it had a problem containing
leachate on site in their trailers and deeply regrets the violation. In 2011 KRD supplied brand new
equipment in efforts to correct and eliminate the issue however failed to recognize after time that
the trailers leak -resistant properties were becoming compromised. KRD is committed to
compliance in this situation and does not want to compromise the facility's ability to ensure
protection of the public health and the environment.
As stated in the NOV, KRD Trucking is required to take corrective action by the issue date of:
September 25, 2014.

The following corrective action plan outlines action already taken as well as proposed action to
ensure continued and effective compliance with section 59.2(c) of Session Law 2013-413.
• Immediately after being informed of the initial results of the inspection KRD assessed the
condition of the trailers located at Burke County and ordered Sludge locks for installation.
(Sludge locks are a screw type mechanism to tighten the door onto the door seal to
enhance water resistant properties)
• Trailer #T-240 and a trailer "believed to be" T-812 were both referred to in the inspection as
leaking trailers. Upon our initial inspection of the trailers T-240 was removed from the Burke
County Transfer for repair (it will not return to Burke County). The North Carolina operation
of KRD does not have a Trailer labeled T-812.
A meeting was held at Burke County Transfer Station on Sept 03, 2014 to discuss the
current status of operations and proposed waste transfer operations to ensure compliance
of permit conditions and the operations plan of Waste Management Facility 12-05T. All
items in this plan were discussed and mutually agreed upon during this meeting. In
attendance for the County was Brock Hall, for Republic Services was Wade Goossens and
Don Phelps and for KRD was Greg Winkler and Scott Barrett.
Inspections and work Completed to date:
o T-767
■ 8-18-2014 inspected floor and body for holes, inspected door seal and
installed two sludge locks at bottom of door. Exhibit 1.0
09-09-2014 two additional sludge locks were installed on door sides and inner
door was welded. Exhibit 1.1
■ Photo Exhibit 1.2
o T-815
o T-817
8-16-2014 inspected floor and body for holes, inspected door seal and
installed two sludge locks at bottom of door. Exhibit 2.0
09-05-2014 two additional sludge locks were installed on door sides and inner
door was welded. Door leak checked with 500 gallons of water. Exhibit 2.1
Photo Exhibit 2.2
08-20-2014 inspected floor and body for holes, inspected door seal and
installed two sludge locks at bottom of door. Exhibit 3.0
09-03-2014 two additional sludge locks were installed on door sides and inner
door was welded. Door leak checked with 500 gallons of water. Exhibit 3.1
Photo Exhibit 3.2

MUM
■ 08-19-2014 inspected floor and body for holes, inspected door seal and
installed two sludge locks at the bottom of door. Exhibit 4.0
■ 09-06-2014 two additional sludge locks were installed on door sides and inner
door was welded. Door leak checked with 500 gallons of water. Exhibit 4.1
Photo Exhibit 4.2
o T-819
■ 08-16-2014 inspected floor and body for holes, inspected door seal and
installed two sludge locks at the bottom of the door. Exhibit 5.0
09-04-2014 two additional sludge locks were installed on door sides and inner
door was welded. Door leak checked with 500 gallons of water. Exhibit 5.1
■ Photo Exhibit 5.2
• All "inner doors" have been welded shut at the bottom in order to eliminate the possibility of
leaking water through the natural gap between panels.
KRD realizes that our industry is harsh on equipment. The loading of MSW into open top
trailers will cause damage to the trailer that ultimately can cause leachate to escape. We
have designed and are proposing for experimental use a Leachate Wagon to be available to
place under any given trailer found to have developed a leak. This Wagon can be placed
under a trailer that has developed a leak and then rolled over to the loading pit to be drained
in an area where leachate is designed to be collected. The wagon is designed with baffles
to reduce spillage when being moved and also has a drain on the underside to allow for
controlled release into designated areas. Exhibit 6.0
In addition to the Leachate Wagon we will have portable spill collection devices available
that may fit in locations where the wagon may not such as near the axles. The same
process will be followed with the use of this Ultra Pop up Pool. Exhibit 7.0
After further discussion with Burke County it was decided that KRD would reverse the
direction of trailer movement through the pit. This would allow for the staging of loaded
trailers on a downward slope in efforts to keep pooled leachate within the trailer off of the
rear door as this is the most susceptible area for leakage. KRD ordered approximately 20
tons of rock in order to provide a stable surface for trailer storage. Exhibits 8.0 and 8.1
• All trailers will be inspected once per week by the maintenance department — deficient
trailers will be removed from the site immediately and repairs completed in a timely fashion.
The inspection form is a two part form and one copy will be left with the Operator at Burke
County and stored in a designated area accessible to the County and Republic Services.
Inspection Form Exhibit 9.0

Inspection schedule and process
■ Weekly inspection will typically occur at the end of every week, preferably
every Friday.
■ Upon identifying deficiencies the inspector will document the deficiency and
notate the expected repairs.
• The equipment in need of repair will be removed from service and taken to the
local KRD shop for said repairs same day.
■ A spare trailer (still to be identified) will be available to replace the trailer taken
out of service to allow for the sufficient level of service at the site.
• Upon completion of said repairs the maintenance technician will document the
repairs on a new inspection form to be matched up with the original notation of
deficiency.
• Under no circumstance will a trailer known to leak be placed back in service
at the Burke County Transfer Station without first being adequately repaired.
■ The original copy of all inspection reports will be maintained at the local KRD
shop in Lenoir NC and also sent electronically to the Regional Manager of
KRD upon completion.
In addition to weekly inspections by the maintenance department, the driver and spotter will
perform daily inspections when operating the equipment. The Spotter will visually inspect
the area under and around the trailer looking for any sign of leaks during the point of both
hooking up and unhooking the trailer. That is before and after it is loaded. The spotter also
will randomly check all loaded trailers throughout the day looking for any evidence of leaks.
If the spotter identifies a leak he/she will first determine if the leachate wagon can be
deployed to collect the leaking water, if the leak is too big for the wagon the spotter will then
move the trailer to the loading pit area or inside the transfer floor area where there is
designated leachate collection points until the driver can remove the trailer for proper
disposal and then repair. The driver will also visually inspect each trailer before and after
tipping at the landfill. While the trailer is empty and in the upright position on the tipper it is
fairly easy to see holes in the bottom as daylight peeking through. The driver will also
inspect the door seal and sludge locks before securing the rear door in the closed position.
KRD shop in Lenoir for repair. The maintenance personnel will then decide if the repair can
be done as the driver waits or if the driver will replace it with the designated spare.
KRD recognizes that proper training of its personnel is essential to the success of any
program. All KRD employees at the Lenoir facility will be trained on this action plan for
Burke County and will be shared with Burke County employees. The training will include the
communication of Burke County's expectation of KRD to comply with the permit
requirements regarding leak -resistant containers. The training will also include all parts of
this plan regardless of the assigned duties of employee so the total scope of KRD's
requirements is understood by all. Training for employees assigned to Burke County will be
completed immediately and all other employees by September 251h 2014. Training
Document Exhibit 10.0

Also, KRD Trucking will make every effort to keep the following trailers at the Burke County
Transfer for easy identification:
• 767
• 815
• 817
• 818
• 819
• Spare still to be determined
If you have any questions or concerns, please contact me.
Sincerely,
John McGee
KRD Trucking
708.774.9917
Attached List of Exhibits
5

List of Exhibits
KRD Response to
NOV Dated 09-25-2014
Burke County NC

KRD Burke County Response Exhibit 1.0
Repair Order
Unit# 7(� 7 Date 6 -[ -Q(W Miles
Repairs Made r� ^
t^kPrt_rrk r'At o LAI ' J II ,t
—Lamp, A ks Eyl PIA � --
.��-t•; -�.^ 4 rr �cC t"�n n^ � n� TAt I FI izNL jh&
Mechanic Lel,.Iis R1St 1 "m Time Start j!tDAm Time End IlICL7oM
Shop Repairr. "IL Road Call Travel Tlme
Part# Description QN
Tire Repair
New Steer Repairable
Cap Drive Failure
Used Trailer
7

KRD Burke County Response Exhibit 1.1
Repair Order
Unit# f Date 1'^/!'!-��e� Miles
Repairs Made
L
�.
Mechanic
Shop Repair �f.�j/ Road Call
New
Cap
Used
Time Start �Time End
Travel Time
Part # Description City
Tire Repair
Steer
Drive
Trailer
0
Repairable
Failure

KRD
Repair Order
unit# --r 'R Date ;E,IL—,2rA4 Miles
Repairs Made -
��cGfCc(�
—Qn� '�Dzn�vtpA F�oplr,%R(r-�ci1 PIA-�-e a�,All..�(
Lkrc6cil I Ica Flut L
Mechanic 0 rem f ), eiL Time Start /.yL7,�„ �_ Time End .LI
Shop Repair�y�.p�j`�' Road Call """'Travel Time
Part # Description qty
Tire Repair -
New Steer Repairable
Cap Drive Failure
Used Trailer
10
Exhibit 2.0

Repair Order
Unite
Repairs Made
KRD Burke
Date Miles �!
Mechanic
Shop Repair hr✓L>�i ��'--�---Road Call
Time Start Z* I Time End T9��M
Travel Time
Part # Description
4ry
Tire Repair
New
Steer
Cap
Repairable
Used
Drive Failure
Trailer
11
Exhibit 2.1

KRD Burke County Response Exhibit 3.0
Repair Order
units T-531% Date aqy Miles
Repairs Made f l 11
1�X. r `Or C C(1C-J<, --I�AI'ra ay B JUr
Mechanic Time Start Q `&)AM Time End /1,WA.4
Shop Repair y- Road Call Travel Time
part s Description qty
Tire Repair
New
Steer Repairable
Cap -
Drive Failure
Used
Trailer
13

KRD Burke CountyRes onse Exhibit 3.1
Repair Order
i Date /
Miles
Repairs Made
71-12
r.. L. ie ✓_
r .aid
� � r
l
Mechanic 4� / //--�//� Time Start
/9✓�,m Time End
Shop Repair Road Call "'�'7""—
�Travel Time
Part # Description
Qty
Tire Repair
New
Steer
Cap
Repairable
Used
Drive Failure
Trailer
14

KRD Burke County Response Exhibit 4.0
Repair Order
Unit# T^A ik Date ai ftaw Miles a
Repairs Made n ff I
i�kecheck �t� R �eAl � ShpileJ
SIk LXkc.
^L nn.LCA r81 Inn- Elfn& h a I1'Ick5
Mechanic
Shop Repair I'�PNfH r Road Call
Time Start y"ItI i„ Time End
Travel Time
Part # Description City
Tire Repair
New Steer
Cap Drive
Used Trailer
16
Repairable
Failure

KRD Burke County Response Exhibit 4.1
Repair Order
UnitN Date q—(g -Aofii Miles��
Repairs Made
Mechanics
i
Shop Repair pNOi2 Road Call
Time Start 6,LbAm Time End
Travel Time
Part # Description Qty
Tire Repair
New
Steer
Cap
Drive
Used
Trailer
17
Repairable
Failure

18

KRD Burke County Response Exhibit 5.0
Repair Order
UnitR �: Date LJ Miles
Repairs Made
r-A64
SI Q'C / CCk e�yy
Mechanic La^ NS ft) r.T 10,& Yb Time Start /Q_ ALn Time End /.lL7AM
Shop Repair LEJWA Road Call Travel Time
Part # Description Qty
Tire Repair
New Steer Repairable
Cap Drive Failure
Used Trailer
19

KRD Burke County Response Exhibit 5.1
Repair Order
Unit# 'T �/9 Date y= -,ap/y Miles
Repairs Made
"YOW— %
G..t �i
Mechanic , js' /�Time Start .%��y yrTime End yliJn�,.,
Shop Repair Road Call Travel Time
Part # Description On
Tire Repair
New
Steer Repairable
Cap
Drive Failure
Used
Trailer
20

21

9rMAVI
_soroyalnauslrzal
KRD Burke County Response Exhibit 7.0
lNraTem llyra Popllp q%i 28 GA -27629- NOfhlnn Safely CA. IN,
1-800-571-4646 maMMsafety CO.A'
For sales®customer service PO Box a2SO,VUra,Nr 13304-2SO
Ftwa•: t-EWS72-+6e
7t30 em-8(00 pm fTKO -srl Fax: 1-900d35-0S01
I
Ultra-PopUp Pool, 20 Gal.
27629
Drop Shio
Secure online ordering
Large volume quotes
$86.84 each
Pricing Guide
Qty Price
Each ;88.84
Description[
captures Leaks from saddle Tanks, Pipes, and Hydraulic Lines
Easy to assemble - just remove from protective case and give it a quick shake, it instantly expands to respond to any emergency.
• Unique foam ring design automatically raises side walls to contain rising spill levels
• Compact folded design stores efficiently inside spill kits
• Ala -polyethylene construction offers exudlent resistance against diesel fuel, and -freeze, acids, caustics, corrosives, and other chemicals
[deal for responding to damaged saddle tanks and cross -over lines, hazmat spills, machinery and pipe leaks
• Also suitable as a decontamination pod and collection pool for soiled sorbents
• Diameten 28° top, 35" bottom
23

24

KRD Burke County Response Exhibit 8.1
PM

KRD Burke County Response Exhibit 9.0
Trailer Inspection Form
Location Date
landing Leak Empty/ Repair
Trailer Tarp Gear Detection Tires Lights Loaded VN
1
Comments
-_-__
r u•t
3
Comments
4
Comments
5
Comments
6
Comments
7
Comments
8
Comments
9
Comments
10
Comments
' Tarp
Checkforteors, mgsfrecly, agstmpspresenr, alllatchas ondwarking
Landing Gear
Chedtfor damage to feet,legs, doss supports, wirgM mavesfreely
Leak Detection
Check sludge lacks,seat anyholes in side orfaar, risible teaks
Tires
check PA tread depth, loak for mismatch dams
Lights
Lights- caking, clean
Inspector Name
26
Signature

KRD Burke County Response Exhibit 10.0
September GS, 2014
KRD Procedures for Leaking Trailers
Burke County Transfer Station NC
KRD is committed to protecting and preserving the health and environment of the communities R
services. All trailers staged at Burke County Transfer Station have been inspected, modified and
repaired as necessary to ensure that they are leak resistant at or above industry standards. However,
our industry is tough on equipment and damage to the trailers that cause leaks are inevitable. The
following steps will be taken by KRD employees to prevent and/or repair leaks found during normal
use.
1_ Weekly inspections will be completed by the maintenance department of KRD to identify any
deficiencies or leaks. if deficiencies or leaks are found during the inspection the equipment will
be immediately removed from service and sent to the KRD Lenoir shop for repair. The carbon
copy of the inspection report will be left with the operator on duty_ If there is a Visible Leak
Follow the teak Mitigation Procedure"
2. KRD spotters will check all units for leaks or do mage every time they hook or unhook to
Equipment. Check to ensure sludge lacks are tight and there is no debris on seal. If there is a
visible leak Follow the Leak Mitigation Procedure*
3. KRD Drivers will walk around the loaded trailer checking for damage or leaks. Driver should
check sludge locks to ensure they are tight. Driver will transport the trailer to the landfill and
empty on tipper- While tipper is up driver will check the bottom of the trailer for visible holes.
Before dosing back door the driver will inspect the seal to ensure it is intact and clean of debris
that may compromise the seal, and then tighten all four sludge locks_ If there is a visible leak
Follow the Leak Mitigation Procedure`
'Leak Mitigation Prozedure-Asses flow anddetermine if the tearlwte wagon, plastic rontainerorspill kit is
necessary to protectfrom releasing leachate on the graund. tf flow is too great jor these devices the troilermay need
to be moved to the pit area or upon last resort the ripping floor. Both areas have permitted and controlled korhate
caflection systems. Notify KRO Supervisor and operator on duty of the leak The trailer will be assigned to the next
availabie driver forimmediate trump on to landfill then to the KRD shop for repair before resuming to Burke County. if
repair will take more than four hours, a spare trailer meeting the leak resistant requirements will be supprred jor
seamless continuation ofservice_
Leachate Wagons are located in pit area and outfined with a drain wives to be drained onfyin the pit area where
there is a permitted and controlled leachate collection system -
Plastic containers are located in the pit area and provided by Burke County far collecting leachate from very small
leaks.
Spill Kits are located in the Lit area andshould only be used when the leak is in an area where are wagon orptastir
containers cannot adequatelyfit andpedform appropriately. Notify the KBDsupervisor when a spill lit is used so a
replacement can be ordered.
27

Attachment 6

&"u ► `c
ENGINEERING
October 6, 2014
Ms. Jackie Drummond
North Carolina Department of Environment and Natural Resources
Division of Waste Management, Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
RE: Soil Assessment Plan
Burke County Transfer Facility; Permit No. 12-05T.
JOYCE Project No. 277.1401.12, Tasks No. 01
Dear Ms. Drummond:
2211 West Meadomiew Rd.
Greensboro, NC 27407
tel: [phone]
fax: [phone]
www.JoyceEngi neering, corn
On behalf of Burke County, Joyce Engineering (JOYCE) submits this Soil Assessment
Plan for the Burke County Transfer Facility, which the County operates under Solid Waste
Permit Number 12-05T. This Soil Assessment Plan is in response to a Notice of Violation
(NOV) issued by the North Carolina Department of Environment and Natural Resources
(DENR) on September 4, 2014. The NOV was issued due to evidence of a release of leachate
from a leaking transfer trailer onto the ground surface at the facility observed during facility
inspections conducted by the DENR in August 2014.
Background
The Burke County Transfer Facility is owned and operated by Burke County and is
located within the property of the John's River Water Management Facility. During an
inspection of the facility on August 4, 2014, the DENR inspector observed a leaking transfer
trailer owned and operated by K. R. Drenth Trucking, Inc., releasing leachate to the paved
surface. The leachate was observed running off of the paved surface into a grassy median, and
there was an area of distressed vegetation interpreted as due to leachate impact. During
subsequent site visits on August 6th and 7th, these observations were confirmed. A Facility
Compliance Inspection Report dated August 25, 2014 reported the details of these observations.
The September 41h NOV called for the County to Submit a Plan for review and approval to the
Section that details a proposed soil assessment for the area impacted by the leaking transfer
trailer.

Ms. Jackie Drummond
October 6, 2014
Page 2 of 3
Apparent Impact Area
According to the August 25`h Inspection Report, the area of apparent impact from the
leachate release measured 21 feet long by 3-5 feet wide. Photos of the apparent impact area
from the August 25`h Inspection Report are included as Attachment 1. Figure 1 (Attachment 2)
presents a Google aerial image of the facility showing the location of the apparent release. The
apparent impact area is in a median surrounded by paved road on all sides. There is no nearby
surface water or storm water discharge that could feasibly be impacted by the release. The
nearest surface water is the head of an intermittent creek located over 300 feet southeast of the
apparent impact area. Groundwater is estimated at 30-40 feet deep in the vicinity of the apparent
impact.
Proposed Soil Sample locations
In order to document the vertical and horizontal extent of impacted soil and the
concentration of solid waste constituents in the impacted soil, we propose collecting soil samples
from five locations in and around the apparent impact area. Figure 2 (Attachment 2) shows the
proposed soil sample locations superimposed on a photo of the impact area from the Inspection
Report. At the two central locations (S-1 and S-2), we propose collecting two samples, one
from a depth of 6-12 inches and one from a depth of 30-36 inches below the ground surface. At
the other locations we will collect one sample from a depth of 6-12 inches. In addition, we will
collect one soil sample from an upgradient location where there is no reason to suspect any
impact from landfill or transfer station operations to represent background soil conditions. Thus
we will collect a total of eight soil samples.
Soil Sampling Protocol
All sampling will be conducted under the supervision of a licensed professional geologist
and will be conducted by trained field personnel. The soil samples will be collected using
stainless -steel hand augers. The sampling equipment will be thoroughly decontaminated before
sampling and between samples. The decontamination procedure will include the following
steps:
• Wash the equipment with a solution of Alconox, or similar phosphate -free detergent,
using a brush, if necessary, to remove particulate matter and surface films;
• Rinse with organic -free water or distilled water twice;
• Air dry on aluminum foil; and
• If not used immediately, wrap equipment in aluminum foil.
Personnel will wear disposable latex or nitrile gloves when handling soil samples. All
samples will be placed in laboratory -prepared sample containers (e.g. Terra Core samplers, jars,
etc.) and put immediately into a cooler with ice for transport to the laboratory.
..1ui ICE
ENGINEERING

Ms. Jackie Drummond
October 6, 2014
Page 3 of 3
Soil Analyses
The samples will be transported to a North Carolina -certified laboratory under chain -of -
custody control for analysis. The soil samples will be analyzed for the NC Appendix I list of
solid waste constituents, including metals by EPA Method 6010, and volatile organic compounds
(VOCs) by EPA Method 5035/8260.
Reporting
A letter report presenting the results of the soil assessment will be submitted to the
DENR. The report will include a description of the soil sampling event, a summary of the
analytical results, the complete laboratory analytical report and chain -of custody, and a
discussion of the results. The report may also offer recommendations for additional sampling,
remediation of the impacted soil, or other actions as appropriate based on the results of the soil
assessment.
Schedule
Soil samples will be collected within 45 calendar days of DENR approval of this Soil
Assessment Plan and will be submitted to the laboratory within analytical method hold times.
The Soil Assessment Report will be submitted to DENR electronically within 45 calendar days
of receipt of the final laboratory analytical report. If you wish to have a hard copy of the report,
we will be happy to provide it upon your request.
Please feel free to contact me at [phone] if you have any questions or comments
regarding this plan. Thank you.
Sincerely,
JOYCE ENGINEERING
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Van Burbach, Ph.D., P.G
Technical Consultant
Attachments
Copy: Brock Hall — Burke County
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ENGINEERINQ

Attachment 1
Page from Facility Compliance Inspection Report
dated August 25, 2014

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 10
1. Leachate leaking onto the asphalt apron from the
semi -trailed filled with municipal solid waste that was
just moved out of the receiving bay. (Photo taken by
B.Wagner 8/04/14)
3. Looking (E) at the area of dead vegetation (2141.
long X 3 to 5-ft. wide) south of the asphalt apron on
the west side of the transfer station. (Photo taken by
B.Wagner 8/06/14)
5. Leachate leaking form hole in the bottom of
trailer #T-240. (Photo taken by B.Wagner 8/07/14)
2. Area of grass that appears to have been killed by
leachate leaking from semi -trailers that are routinely
stabbed on asphalt apron on the WSW sided of the
transfer station. (Photo taken by B.Wagner 8/04/14)
4. Looking (S) at what is believed to be leachate that
has recently leaked onto the asphalt apron on the west
side of the transfer station, from a transfer trailer filled
with municipal solid waste, that has been moved off -
site. (Photo taken by B.Wagner 8/06/14)
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6. Leachate leaking from hole in the bottom of
trailer #T-240, pooling on the asphalt apron. (Photo
taken by B.Wagner 8/07/14)

Attachment 2
Figures 1 & 2