0803_Action Plan_June 18-2021

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MEMORANDUM
To: Joe Dehner, General Manager
From: Matt Einsmann, PE, Environmental Manager
Date: June 17, 2021
Reference: West Slope Berm and Downdrain Project
Introduction and Objective
This Action Plan has been assembled to describe the actions proposed to be completed by Republic Services to
address the observed violation regarding cover material requirements as noted in the inspection completed by
Solid Waste Section staff on February 22, 2021. The objective of the proposed work is to place soil cover over
the western slope of Cells 4 through 12 to satisfy the regulatory requirement for cover and to construct a
stormwater conveyance system that will minimize future stormwater infiltration.
Description of Project
A project design was completed with the following tasks:
• Place 6-inches of soil cover over approximate 34-acre slope
• Construct approximately 5,770 lf of stormwater diversion berms
• Install approximately 1,470 lf of downdrain pipe
• Place approximately 28,200 sy of matting (around down drainpipes and berms)
• Sow grass over approximate 34-acre slope
• Excavate/place soil in the perimeter ditch as necessary to establish the proper flow of the stormwater
conveyance system
The project design is shown graphically below.
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Soil Remediation
During the ditch portion of the project and in areas where leachate was dammed for short periods of time
(shown graphically in the picture below), Republic Services will excavate soil below the current land surface.
Following removal of this soil, Republic Services, through a third-party consultant, will advance a
decontaminated stainless-steel hand auger to a depth of 2-feet below the ground surface and collect a discrete
soil sample from the 1-foot to 2-foot interval. Soil samples will be collected approximately every 100 feet along
the flow line of the ditch in the areas shown. A potion of the retained soil will be placed in a zip-lock baggie and
field screened with a RKI-GX-6000 Gas Meter equipped with LEL, O2, H2S, CO, and NH3 sensors. The third-party
consultant will record the field screening data in a field book. The remainder of the collected soil will be
immediately placed in laboratory supplied bottles, placed in a cooler containing ice, and transported under
proper chain-of-custody procedures to Pace Analytical, a North Carolina certified laboratory, for analysis by the
following parameters:
40 CRF Part 259 Appendix I Parameters – volatile organic compounds (VOCs) by EPA Method 8260;
40 CFR Part 258 Appendix I Parameters – Appendix I metals by EPA Method 200.7/245.1;
Total Phosphorus by EPA Method 365.2;
Sulfate by EPA Method 9056A;
Nitrate-Nitrogen by EPA Method 9056A; and
pH / Corrosivity by EPA Method 9040D.
Each boring location will be surveyed with a sub-meter Trimble GPS unit. One background soil sample will also
be collected and sampled under the procedures noted above. Soil that is excavated from the perimeter ditch
will be transported to the active portion of the landfill and buried with the daily waste. Following receipt of the
analytical report, Republic Services, through the third-party consultant, will prepare a summary report and
submit the report to NCDEQ.
Timeline
Beginning June 21, 2021, Republic Services will use in-house personnel to complete the northern and middle
sections of the project. It is anticipated that this work will require four weeks to complete.
Throughout the remainder of the year, Republic Services will complete the southern section of the project with
the goal of having that section completed by the end of the calendar year.