4406_INSP_20231205

NORTH CARnLINAD_E Q��
o.n.mm.m m c.w.mmen.i a.i�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: HAYWOOD
MSWLF
PERMIT NO.: 4406-INDUS-1984
Closed
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
X
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: 12/05/2023
FACILITY NAME AND ADDRESS:
Landfill No. 6
1155 Incinerator Rd
Canton, NC 28716
Date of Last Inspection: 08/23/2023
GPS COORDINATES (decimal degrees): Lat.: 35.548508' Long.:-82.876149'
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Charles Howell
Telephone: [phone]
Email address: charles.howell(kpactivevergreen.com
FACILITY CONTACT ADDRESS:
1900 W. Field Court
Lake Forest, IL 60045
PARTICIPANTS:
Tracy Willis, Pactiv Evergreen
Lee Hill, NCDEQ — Solid Waste Section
STATUS OF PERMIT:
Life of Site permit issued October 26, 2018
Permit to Operate Expires March 28, 2044
Permit to Operate Landfill No. 6 Area E issued July 21, 2021
PURPOSE OF SITE VISIT:
Partial Inspection
STATUS OF PAST NOTED VIOLATIONS:
N/A
OBSERVED VIOLATIONS:
A. 15A NCAC 13B .0505(a)(5)(C) states: "Laachate shall be contained on site or treated prior to discharge. A
National Pollutant Discharge Elimination System (NPDES) permit issued by the Department of Environmental
Quality, Division of Water Resources in accordance with 15A NCAC 02B may be required prior to the discharge
of leachate to surface waters. "
On the afternoon of December 4, 2023, Charles Howell, with Pactiv Evergreen called to report a release of
leachate from the Landfill No. 6 leachate ponds. Mr. Howell stated that the western most leachate pond had
overflowed. Mr. Howell stated that they did not know how long or how much leachate had been discharged into
the environment. A field inspection was conducted with Tracy Willis on December 5, 2023. Mr. Willis stated
that he had been called to the site on Monday morning due to a report of a leachate release. Mr. Willis stated that
upon arriving to the site, the high-level alarm was activated and that both leachate pumps were in the off position
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
OepaNnent W Environnrenbl puelily
Solid Waste Section
and were not pumping leachate. During the inspection, two areas where leachate overtopped the western most
pond were observed. One area was approximately 40 feet wide, and the other area was approximately 24 feet
wide. The ground was saturated in these areas. Gray staining/residue was observed on the ground. The leachate
ponds are located approximately 120 feet from the bank of the Pigeon River. The area near the river was
inspected and there were no observations or evidence indicating that leachate reached the river.
Blue Ridge Paper Products LLC is in violation of 15A NCAC 13B .0505(a)(5)(C) for failing to contain
leachate on site prior to treatment and discharge.
To correct the violation, Blue Ridge Paper Products LLC shall contact Elizabeth Werner, Hydrogeologist to
determine the requirements for a soil sampling plan to determine the impact of the leachate release. Pending the
laboratory analytical results, additional measures may be required.
Elizabeth Werner, Hydrogeologist
NCDEQ-Division of Waste Management
919-707-8253
elizabeth.werner(c�r�deq.nc.gov
B. 15A NCAC 13B .0203(d) states: By receiving solid waste at a permitted facility, the permittee shall be
considered by the Department to have accepted the conditions of the permit and shall comply with the conditions
of the permit. "
Permit to Operate 4406-INDUS-1984, ATTACHMENT I, PART I GENERAL PERMIT CONDITIONS, Number
6 states: "Construction and operation 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.), the conditions contained in this permit; and the approved plan. Should the approved
plan and the rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed
by permit condition. Failure to comply may result in compliance action or permit revocation."
The approved Operations Plan (File ID No. 1795867), Operations and Maintenance Manual Landfill No. 6 -Area
D and Area E, 4.4, Leachate Flow Control states: "The leachate transport piping system between the Landfill and
the wastewater treatment plant is designed with gate valves to control the flow if necessary. The following
scenarios are described with the proper actions to be taken.
The leachate transport system includes a lift station with the capacity to handle and pump up to 200 gpm
of leachate flow. If this capacity is exceeded, the leachate flow in excess of 200 gpm will be directed to
the leachate storage ponds. There are no actions required by the Landfill Operator for this scenario. Once
the flow falls below 200 gpm, the ponds will begin to empty.
In the event the leachate transport pipe from the lift station to the treatment plant develops a leak, pipe
break, blockage, or the pump station needs maintenance, the transport pipeline can be shut off. A gate
valve located on the outlet of the pond can be closed thereby allowing the ponds to fill. Leachate flow will
then be temporarily stored in the leachate storage ponds while the problem is solved."
During the field inspection conducted with Tracy Willis on December 5, 2023. Mr. Willis stated that he had been
called to the site on Monday morning due to the leachate release. Mr. Willis stated that upon arriving to the site,
the high-level alarm was activated and that both leachate pumps were in the off position and not pumping
leachate.
Blue Ridge Paper Products LLC is in violation of 15A NCAC 13B .0203(d) for failure to operate the
leachate collection system as stated in the approved Operations Plan, Operations and Maintenance Manual
Landfill No. 6 Area D and Area E, 4.4, Leachate Flow Control.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
Ow-- W Emironm l puelily
Solid Waste Section
To correct the violation, Blue Ridge Paper Products LLC must operate the leachate collection in accordance with
the approved Operations Plan, Operations and Maintenance Manual Landfill No. 6 -Area D and Area E, 4.4,
Leachate Flow Control. To prevent leachate pond overflow in the future, the facility shall implement a procedure
to inform the relevant personnel in a timely manner of a pump failure or that the pumps have been turned off. This
procedure shall be submitted to Elizabeth Werner, Hydrogeologist.
Leachate Overflow Location on South Side of Leachate Pond
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NORTH CARnLINAD_E Q��
o.n.mm.m m c.w.mmen.i a.i�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Leachate Overflow Location on Southwest Side of Leachate Pond
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.
ADDITIONAL COMMENTS
1. All photos were taken by Lee Hill on December 5, 2023.
2. On September 14, 2023, Charles Howell emailed the Section with the following updated permittee and contact
information for Landfill No. 6: `Blue Ridge Paper Products LLC, which is a wholly owned subsidiary of
Evergreen Packaging LLC, which is a wholly owned subsidiary of Pactiv Evergreen Inc."
3. On the afternoon of December 4, 2023, Charles Howell, with Pactiv Evergreen called to report a release of
leachate from the leachate ponds. Mr. Howell stated that western most leachate pond had overflowed. Mr.
Howell stated that they did not know how long or how much leachate had been discharged into the
environment. Mr. Howell was sent the "Leachate Release Sampling & Analysis Guidelines" by email and was
told to contact Elizabeth Werner, Hydrogeologist about the release. Mr. Howell reached out the Ms. Werner by
phone and email to begin the process of leachate release sampling.
4. A field inspection was conducted with Tracy Willis on December 5, 2023. A leachate release was observed in
two areas western most leachate pond. Please see Observed Violations section of this report.
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FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
OepaNnent W Environnrenbl puelily
Solid Waste Section
5. An inspection of the perimeter of the landfill was conducted and no leachate or other issues were observed at
that time.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Lee Hill
c cn=Lee Hill, o=Solid Waste
Section,
ou=Field Operations
Branch,
email=[e-mail], c=US
Date: 2023.12.12 17:34:30-05'00'
Lee Hill
Environmental Senior Specialist
Regional Representative
Phone: [phone]
Sent on: December 12, 2023
X
Email
and delivery
US Mail
X
Certified No.
7022 2410 0003 1437 1832
Copies: Jason Watkins, Field Operations Branch Head — Solid Waste Section
Deb Aja, Western District Supervisor — Solid Waste Section
Chris Hollinger, Compliance Officer — Solid Waste Section
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