8807_TransylvaniaCountyMSWLF_SAP_26253_20160212

Environmental Engineers, Scientists & Consultants 2211 West Meadowview Rd.
Greensboro, NC 27407
tel: [phone] fax: [phone] www.JoyceEngineering.com
February 12, 2016

Mr. Ervin Lane
Compliance Hydrogeologist North Carolina Department of Environmental Quality Division of Waste Management, Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
RE: Soil Assessment Plan Woodruff Landfill; Permit No. 8807 MSWLF-1990. JOYCE Project No. 336.1601.12, Tasks No. 03

Dear Mr. Lane:
On behalf of Transylvania County, North Carolina, Joyce Engineering (JOYCE) submits this
Soil Assessment Plan for the Woodruff landfill Facility, which the county operates under Solid
Waste Permit Number 8807. This Soil Assessment Plan is in response to a Notice of Violation (NOV) issued by the North Carolina Department of Environmental Quality (NCDEQ) Solid Waste Section (SWS) on April 5, 2016. The NOV was issued due to evidence of a release of
leachate from a landfill working face and into the stormwater ditch observed during facility
inspections conducted by the SWS on March 18, 2016.
Background
The Woodruff Landfill is owned and operated by Transylvania County. The landfill is located in
Rosman, North Carolina. During an inspection of the facility on March 18, 2016, the SWS
inspectors observed a release of leachate from the working face and into to a stormwater ditch. The April 5th NOV called for the Transylvania County to contact Ervin Lane, Compliance
Hydrogeologist within 10‐days of receipt of the Notice of Violation, to determine the requirements for a soil sampling plan to investigate the extent of the leachate release and corrective measures.

Apparent Impact Area
According to the March 18, 2016 Inspection Report, the area of apparent impact from the leachate release is the working face and allowing leachate to leave the lined disposal cell and to
flow into a stormwater ditch. The nearest surface water is the Woodruff Branch located
approximately 400 feet west of the apparent impact area. Groundwater is estimated to be
approximately 16 to 19 feet deep in the vicinity of the apparent impact.
Mr. Ervin Lane
April 12, 2016
Page 2 of 3

Proposed Soil Sample locations
In order to document the extent of possible impacted soil and the concentration of leachate
constituents in the soil, we propose collecting soil samples from four locations, three in the apparent impact area plus one background sample. The lower photo on page 4 of 12 in the
Inspection Report (3/18/2016) shows the edge of waste marker and the stormwater channel. The
proposed sample locations will be collected in this area based on observed soil staining or other
evidence of impact. At each location, we will collect one sample from a depth of 12-24 inches.

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 sampling will be conducted in order of
background sample, the least contaminated to the most contaminated. The soil samples will be collected using a stainless-steel hand auger. The sampling equipment will be decontaminated before sampling and between samples. The decontamination procedure will include the
following steps:
• Wash the equipment with a solution of phosphate-free detergent (Alconox), using a brush
to remove particulate matter and surface films;
• Rinse twice with organic-free water or distilled water;
• 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.
Soil Analyses
In accordance with SWS instructions dated April 11, 2016, soil samples should be analyzed for
Appendix I VOCs and metals plus BOD, COD, and phosphorus. The results of the soil
analytical data will be compared to the Residential Preliminary Soil Remediation Goals (PSRGs) or the Protection of Groundwater PSRGs listed in the Inactive Hazardous Sites Branch Preliminary Soil Remediation Goals.

The samples will be transported under chain-of-custody control for analysis to a North Carolina-
certified laboratory that has reporting limits either at or below the Residential and Protection of Groundwater PSRGs
Reporting
A letter report presenting the results of the soil assessment will be submitted to the SWS. The
report will include a description of the soil-sampling event, a map showing the soil sample locations, a summary of the analytical results, the complete laboratory analytical report and chain-of-custody, and a discussion of the results. The report will compare the analytical results
Mr. Ervin Lane
April 12, 2016
Page 3 of 3

to the NCDEQ Inactive Hazardous Sites Branch Preliminary Soil Remediation Goals (PSRGs).
The report may also offer recommendations for additional sampling, remediation of impacted
soil, or other actions as appropriate based on the results of the soil assessment.
Schedule
Soil samples are scheduled to be collected during the last week of April 2016 upon SWS
approval of this Soil Assessment Plan. Soil samples will be submitted to a NC-certified
laboratory within analytical method hold times.
The Soil Assessment Report will be submitted to SWS electronically within 15 workdays (21
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

Hannu Kemppinen, P.G Senior project Consultant

Attachment: March 18, 2016 Facility Compliance Inspection Report
Copy: Jeff Brookshire, Director of Solid Waste, Transylvania County

Attachment

Facility Compliance Inspection Report
March 18, 2016

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 12

UNIT TYPE:
Lined MSWLF X LCID X YW Transfer Compost SLAS COUNTY: TRANSYLVANIA
Closed MSWLF HHW White goods X Incin T&P FIRM PERMIT NO.: 8807
CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 03/18/2016 Date of Last Inspection: 09/18/2014

FACILITY NAME AND ADDRESS:
Transylvania Municipal Solid Waste Landfill Facility 500 Howell Rd
Brevard, NC 28712
GPS COORDINATES: N: 35.11860° W: 82.8466°
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Jeff Brookshire, Transylvania Solid Waste Director
Telephone: [phone]
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS: Jeff Brookshire, Transylvania County
Pete Stamey, Transylvania County
Vickie Guy, Transylvania County Deb Aja, NCDEQ, Solid Waste Section
Lee Hill, NCDEQ, Solid Waste Section STATUS OF PERMIT:
Permit to Operate issued July 16, 2013
Operations Plan approved April 6, 2010 Permit expires July 16, 2018

PURPOSE OF SITE VISIT:
Comprehensive Audit
STATUS OF PAST NOTED VIOLATIONS:
N/A
OBSERVED VIOLATIONS:
15A NCAC 13B .1626(2)(a) states “Except as provided in Sub-Item (b) of this Item, the owners or operators of all
MSWLF units must cover disposed solid waste with six inches of earthen material at the end of each operating day, or at
more frequent intervals if necessary, to control disease vectors, fires, odors, blowing litter, and scavenging.”
15A NCAC 13B .0203(d) states in part: “…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.” The approved operations plan “Woodruff Landfill, Phase 5 Transylvania County, North Carolina Operations Plan revised
March 2010” (DIN 10329) states in section 5.4. (Daily Cover) “At the end of each day's operation, compacted waste in
the subcell will be covered with either a minimum six inches of soil, or a tarp (previously approved as an alternative daily
cover). When a tarp is used, the minimum of six inches soil cover will be placed once a week. The cover soil placed
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 12

weekly shall be compacted with minimum of two passes with the compactor. Waste may be covered more frequently than
once per day if necessary to control fires, odors, or blowing litter.”
Transylvania County is in violation of 15A NCAC 13B .1626(2)(a) and 15A NCAC 13B .0203(d) by failing to cover all waste at the end of each working day (working face, previous daily cover, and along access road).
15A NCAC 13B .1626(7)(b) Adequate sediment control measures (structures or devices), shall be utilized to prevent on-site erosion.
15A NCAC 13B .0203(d) states in part: “...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.” Attachment
3, Conditions of Permit to Operate, Part I, #2 states that “All sedimentation and erosion control activities must be
conducted in accordance with the Sedimentation Control act N.C.G.S. 113A-50, et seq., and rules promulgated under 15A NCAC 4.
Transylvania County is in violation of 15A NCAC 13B .1626(7)(b) and 15A NCAC 13B .0203(d) by failing to establish a groundcover sufficient to restrain on-site erosion.

Erosion on northwest slopes. 15A NCAC 13B .1626(8)(b) Surface water shall not be impounded over or in waste.
15A NCAC 13B .0203(d) states in part: “…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.” The
approved operations plan “Woodruff Landfill, Phase 5 Transylvania County, North Carolina Operations Plan revised
March 2010” (DIN 10329) states in part in section 8.1 “General” “Surfacewater shall be diverted from the operational area and shall not be impounded over or in waste.”

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 12

Transylvania County is in violation of 15A NCAC 13B .1626(8)(b) and 15A NCAC 13B .0203(d) by failing to divert surface water and allowing it to be impounded on waste.

Impounded water on top of landfill.

15A NCAC 13B .1626(8)(d) Leachate shall be contained within a lined disposal cell or leachate collection and storage system. All leachate shall be treated, as required by the receiving facility, prior to discharge.
Transylvania County is in violation of 15A NCAC 13B .1626(8)(d) by allowing leachate to leave the lined disposal cell.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 12

Leachate pit with exposed waste. Leachate, sediment and trash flowed down gradient past edge of waste markers to
stormwater conveyance system. (Photo taken by Deb Aja on March 18, 2016)

Edge of Waste Marker
Approximate location of leachate pits.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 12

Trash and leachate off of the liner. (Photo taken by Deb Aja on March 18, 2016)

Trash and leachate off of the liner flowing to stormwater conveyance system. (Photos taken by Deb Aja on March 18, 2016)

15A NCAC 13B.1626(11)(a) MSWLF units shall restrict solid waste into the smallest area feasible.
Transylvania County is in violation of 15A NCAC 13B .1626(11)(a) by failing restrict solid waste into the smallest
area feasible in that the waste could not be properly compacted and covered at the end of each working day.
15A NCAC 13B.1626(11)(b) Operational Requirements for MSWLF Facilities Solid waste shall be compacted as densely
as practical into cells.
Transylvania County is in violation of 15A NCAC 13B .1626(11)(b) by failing to confine waste into cells of such size that they can be properly compacted.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 12

Near vertical working face.
Working face.
15A NCAC 13B.1626(11)(c) Methods such as fencing and diking shall be provided within the area to confine solid waste
subject to be blown by the wind. At the conclusion of each day of operation, all windblown material resulting from the
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 7 of 12

operation shall be collected and returned to the area by the owner or operator.
15A NCAC 13B .0203(d) states in part: “…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.” The approved operations plan “Woodruff Landfill, Phase 5 Transylvania County, North Carolina Operations Plan revised
March 2010” (DIN 10329) states in part in section 3.6 “Litter Control” “Temporary fences and/or dikes may be
constructed to contain windblown material during operations. In addition, landfill personnel will pick up windblown litter as necessary along the access road and around the active disposal area.”

Transylvania County is in violation of 15A NCAC 13B .1626(11)(c) and 15A NCAC 13B .0203(d) by failing to collect all windblown material and return it to the area at the conclusion of each day of operation.

Windblown litter. (Photo taken by Deb Aja on March 18, 2016)

ADDITIONAL COMMENTS
1. All photos were taken by Lee Hill on March 18, 2016 unless otherwise noted. 2. The facility is owned, managed and operated by Transylvania County.
3. The facility service area is limited to Transylvania County.
4. The hours of operation for the facility Monday through Saturday, 8:00am to 4:00pm.
Records Review
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.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 8 of 12

5. Both the current permit and operations plan were available upon request.
6. Waste Screening reports from November 2015 to March 2016 were reviewed. Screenings appeared to be performed with good frequency and provided good documentation of observed unacceptable waste streams and
final disposition of those wastes. 7. Incoming tonnage records from November 2015 to March 2016 were reviewed and the facility averaged 63 tons
of waste per day.
8. Groundwater monitoring report dated January 19, 2016 for sampling dates of October 19 through 21, 2015 was available for review. Monitoring wells M4 and M7 were abandoned during phase 4 construction.
9. Leachate daily inspection forms were reviewed. These forms are completed daily and include the number of
loads of leachate which are hauled to Rosman Wastewater Treatment Plant.
10. Manager of Landfill Operations
 Jeffrey Gaston Brookshire (expires 06/15/2016)
11. Certified Landfill Operations Specialists
 James Darrell McCall (expires 04/15/2017)
 Vickie Guy (expires 03/04/2019)
 Joseph A. Wiggins (expires 03/04/2019)
 Pete Stamey (expires 04/27/2016) 12. Leachate line inspection and cleaning was completed in July 2015.
13. Scrap tire forms were reviewed and appeared to be filled out correctly.
Operations inspection of MSWLF unit (8807) 14. Waste was being placed on the south side of phase 2 at the time of the inspection.
15. The working face was larger than the tarps used as an approved alternative daily cover and the working face slope was close to vertical at the time of inspection. Mr. Stamey stated that they had not covered all the waste
the previous night (3/17/2016). Good compaction could not be achieved with a steep working face.
16. Standing water was observed on the top of the landfill to the northwest of the working face. See observed violation section of report.
17. Two leachate pits were dug near the toe of the working face. Leachate was observed flowing into one pit.
Trash was exposed in both pits. Leachate, trash and sediment had moved from the pits and landfill side slopes off of the landfill liner system and into the stormwater conveyance system. See observed violation section of
this report. 18. Windblown material was observed on all areas of the landfill. See observed violation section of this report. 19. Large rocks and saprolite were observed in the cover soil. This material is unsuitable for cover soil without
being screened.
Rocks and saprolite soil cover.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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20. Exposed waste was observed where areas of the daily cover soil had eroded. 21. An access road had been installed on the west side of landfill resulting in exposed waste and erosion. See
observed violations section of this report (failure to cover and excessive erosion).
Exposed waste and excessive erosion at access road.
22. Leachate was observed leaving the liner area on the south side of the landfill. See observed violation section of this report. 23. Multiple leachate seeps were observed on the northwest, southwest and south slopes of the landfill. Leachate
seeps must be repaired to ensure that leachate does not leave the landfill liner system.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 10 of 12

Leachate seeps.
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Division of Waste Management
Solid Waste Section
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Leachate seeps.

Leachate seeps.
24. Edge of waste (EOW) markers were installed at the time of inspection. It was stated that edge of waste (EOW)
were placed 10 feet inside of liner system.
25. The leachate tank and secondary containment was inspected and found to be well maintained and the secondary containment valve was closed.
26. The leachate level at the time of inspection was 14’4’.
27. Maintenance on the leachate pump and tank float was performed on March 17, 2016.
Operations inspection of white goods area.
28. White goods and scrap metal are stored on a concrete pad to the northwest of the scalehouse. 29. White goods are sent to Asheville Metal in Asheville for refrigerant extraction and recycling. Please ensure
that units containing CFC’s are stored in a manner to prevent the discharge of refrigerant gases.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 12 of 12

Operations inspection of LCID landfill 30. The LCID landfill unit is closed and is used for a treatment and processing pad for grinding.
31. The LCID landfill was not fully inspected however small tree growth was observed on the side slopes. Trees should be removed from the side slopes of the landfill to ensure the integrity of the cap is preserved. 32. Unacceptable material is removed by facility staff prior to adding the material to the stockpile.
Other comments 33. The Household Hazardous Waste and tire collection areas were inspected.

Please contact me if you have any questions or concerns regarding this inspection report.

_______________________________ Phone: [phone]

Lee Hill Environmental Senior Specialist
Regional Representative

Sent on: April 5, 2016 to Jeff Brookshire and Jamie Laughter by
X Email Hand delivery US Mail X Certified No. [7014051000004663494]

Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Deb Aja, Western District Supervisor - Solid Waste Section
Jessica Montie, Compliance Officer – Solid Waste Section
Sarah Rice, Compliance Officer- Solid Waste Section Jaime Laughter, County Manager