8805_ROSCANS_2002

North Carolina
Department of Environment and Natural Resources
Division of Waste Management
Michael F. Easley, Governor
William G. Ross Jr;, Secretary
Dexter R. Matthews, Director
Mr. Mike Cody
Environmental Affairs
RFS Ecusta, Inc.
One Ecusta Road
October 16, 2002
Pisgah Forest, N.C. 28768
RE: Water Quality Monitoring At Ecusta Landfills
Permits $8-01 and 88-05
Dear Mr. Cody,
&~ _.,: --., ... __ ...
NCDENR ·
Thank you for the opportunity of meeting with you this past
month to review the status of Ecusta' s Ash Landfill (88-01) and
Process Waste Landfill (88-05). As we discussed at that time
water quality monitoring is required at landfills even after
closure. · Following is a summary of water quality monitoring
requirements for each of the two Ecusta Industrial Landfills.
88-01 Ecusta Ash Landfill
The ground and surface water monitoring shall continue on at
least a semi-annual basis. Sampling and analyses shall be done for
each of the following ground-water monitoring wells: Q88V2, Q88V3,
Q88V4, Q88V5, Q88V6 and each of the four new monitoring wells; the
deep well paired with well Q88V5, the deep well paired with well
Q88V6, and a shallow and deep well paired together midway between
wells Q88V5 and Q88V6, for a total of nine wells. In addition to
water samples taken from the monitoring wells, four additional
water samples should be taken at the following locations: Samples
should continue to be taken upstream and downstream on Thrash
Branch, from the outlet for the underdrains, and from the ground-
water collection pipe for the trench running inside the slurry
wall. Each water sample shall continue to be analyzed for the
following constituents: Arsenic, Cadmium, Chromium, Conductivity,
Iron, Lead, Manganese, Mercury, pH, Selenium, Temperature, Total
Sulfates, TDS, and TOC.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED I 10% POST CONSUMER PAPER
Mr. Mike Cody
Ecusta Landfill Monitoring
Page 2
In addition to the water quality sampling, water table
measurements shall be made for the piezometers within the ash
landfill. Water table measurements, and the calculated water
elevations based upon these measurements, shall be provided for
each of the nine monitoring wells and each of the piezometers
within the ash disposal area. This information shall be included
in the report for each required semi-annual sampling event.
As of this date, the Solid Waste Section has not received the
water quality data for the complete monitoring system, including
the new wells installed to measure the effectiveness of the slurry
wall. This data needs to be submitted immediately. Also, the next
scheduled semi-annual sampling event is due next month (November).
Sampling and analyses shall be done for each sampling location, as
outlined in this letter, for both the Ash Landfill and the Process
Waste Landfill, and the data shall be sent to the Solid Waste
Section as soon as possible.
88-05 Ecusta Process Waste Landfill, the "Island Landfill"
It was my understanding that after the Superfund study done in
the early 1990s, that three of the monitoring wells would be
retained at the "Island Landfill" to provide routine detection
monitoring for the Solid Waste Section. There were several
discussions with Mr. Bob Gussman of Ecusta regarding this matter.
It had been my understanding that there had already been an
agreement from the time of the early 1990s that Ecusta would sample
these three wells in addition to doing surface water sampling at
the "Island Landfill" site. In any event, in a telephone
conversation with Mr. Gussman in February 1997, he formally
committed Ecusta to performing semi-annual water quality monitoring
for three detection monitoring wells (designated MW-1, MW-2, and
MW-5) and three surface water monitoring locations around the
"Island Landfill". As of this date, Ecusta has never submitted any
ground-water or surface water data to the Solid Waste Section for
the Process Waste Landfill.
I observed during my field visit that MW-5 has been damaged.
This well needs to be properly abandoned according to the Rules for
"permanent abandonment of wells", 15A NCAC 2C .0113(a) (2). This
well needs to be replaced with a new monitoring well. It would be
better to relocate this replacement well approximately 400 feet
west of the existing well location, so it will not be below the
sediment basin. Please contact me to confirm the exact location
and design of the replacement monitoring well prior to well
installation.
Mr. Mike Cody
Ecusta Landfill Monitoring
Page 3
Because Ecusta is years behind in collecting water quality
data for the "Island Landfill", it is important that water quality
monitoring be established immediately. A minimum of semi-annual
monitoring shall be performed for each of the three monitoring
wells (MW-1, MW-2, and the replacement for MW-5) and each of the
three surface water monitoring locations (upstream Davidson River,
Turkey Creek, and downstream Davidson River), as shown on Drawing
S-1610-E-5, the Monitoring Location Map, prepared by RMI, Inc. as
part of the October 29, 1997, submittal by Ecusta for the Process
Waste Landfill.
As referenced on the top of Page 6 of my letter of July 9,
1998, to Mr. Gussman of Ecusta, the sampling parameters proposed in
the October 29, 1997, submittal by Ecusta (pH, Temperature,
Conductivity, Total Dissolved Solids, Iron, Manganese, and TOC)
need to be expanded to include RCRA metals, Sulfates, a voe scan
(using EPA Method 8260), and a SVOC scan (using Method 8270). Next
month's scheduled semi-annual sampling event should be performed
for the two functioning monitoring wells (MW-1 and MW-2) and the
three surface water sampling locations. The replacement well for
MW-5 needs to be installed prior to next Spring's scheduled
sampling event.
In this letter I have briefly summarized the water quality
monitoring requirements for the two Ecusta Industrial Landfills
currently permitted by the Solid Waste Section. If you have any
questions regarding this letter, please call me at [phone],
extension 258.
Sincerely,
Bt:!:z:(;ift
Hydrogeologist
Solid Waste Section
cc: Jim Coffey
Jim Barber
Mark Poindexter
Larry Rose
Jim Patterson
Nancy Scott
Central Files
Solid Waste Section
Solid Waste Section
Solid Waste Section
Solid Waste Section
sws -Asheville
NC AG Office
.~,.;~ revised 08/30/02 2:12 PM ~·· ---·~ . m ,a .;,~
NCDENR
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
NORTH CA.ROLINA DEPARTMENT OF
ENVIRONMENT ANO NATURAL RESOURCES
UNIT TYPE: (check all that ap Jly to this-audit with same Pennitnumber)
Lined LCID YW Transfer Compost SLAS
MSWLF
Closed HHW White Inc in T&P FIRM
MSWLF goods
CDLF Tire T&P I Tire Industrial x DEMO SDTF
Collection Mono fill Landfill
. ·
COUNTY: Tra!1sylvania
PERMIT NO.: aa~os
FILE TYPE: COMPLIANCE
Date of Audit: 08/23/02 Date of Last Audit: 07 /l 0/02
FACILITY NAME AND ADDRESS:
RFS Ecusta, Inc.
State Road 1512
Pisgah Forest, NC 28768
FACILITY CONTACT NAME AND PHONE NUMBER:
Mike Cody, Director of Environmental Health and Safety
Telephone: [phone]
FACILITY CONTACT ADDRESS {IF DIFFERENT):
Mike Cody, Director of Environmental Health and
Safety
RFS Ecusta, Inc.
P.O. Box 200
Pisgah Forest, NC 28768
AUDIT PARTICIPANTS:
Jim Patterson, N.C. Solid Waste Section
Mike Cody, RFS Ecusta, Inc.
STATUS OF PERMIT:
Active
PURPOSE OF AUDIT:
Inspection of industrial landfill (process waste).
NOTICE OF VIOLATION{S) (citation and explanation):
.
I SA North Carolina Administrative Code 13B .0505(B)(a) states that solid waste shall be covered after each day of
operation with a compacted layer of six inches of suitable cover or as specified by the Division. RFS Ecusta, Inc. was
operating in violation of this rule in that solid waste was not covered as required by the facility pennit.
By September 16, 2002, cover all exposed solid waste including the land-clearing material, office trash, and waste
exposed by weather on the landfill working face with at least 6 inches of cover material.
You are hereby advised that, pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $5,000 per day may be assessed for each
violation of the Solid Waste Statute or Regulations. If the violation(s) noted here continue, you may 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 AUDIT REPORT
Division of Waste Management
Solid: Waste Section
Page 2 of2
STATUS OF PAST NOTED VIOLATIONS (List all noted last audit):
NIA
OTHER COMMENTS /SUGGESTIONS:
(I) This RFS Ecusta landfill has stopped receiving waste.
(2) Within six (6) months, the landfill must be closed in accordance with the closure plan for this landfill if the
facility remains inactive.
Please contact me if you have any questions or concerns regarding this audit report.
Regional Representative
Distribution: original signed copy to facility --signed copy to compliance officer -e-mail or copy to super
Delivered on : 09/03/02 by hand delivery x US Mail Certified No. (Z 372 690 547] : I
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c delivered. Consul_t postmaste_r for fee. io i ~ ~.3~.~A~rt~ic~le-A~d~d~re-s_s_e~d~to-:~~~~~~------~--.-~4a-.~A~rt~ic~le-:-;N~u-m~b-er~----~~----~~ ) l i Mike c'ody~ Director of Env. Health & Safety \ 2 31 t,l. b ~ 0 S Y. 1 i 8 I RFS Ecusta, Inc. : 4b. Service Type
I u IP.O. Box 200 1 D Registered lgj Certified
I ffi !Pisgah Forest, NC 28768 , D Express Mail D Insured
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US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided. ·
Do not use for International Mail (See reverse)
Mike Cody, Director of Env. Health & Safety
RFS Ecusta, Inc.
P.O. Box200
Pisgah Forest, NC 28768
---·
Certified Fee
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r-A revised 07112/02 5:52 PM
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NCDENR
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
NORTH CAROLINA 0EPARTMitNT OF"
ENVIRONMENT AND NATURAL RESOURCES
UNIT TYPE: (check. all that apply to this audit with same Pennitnumber),
Lined LCID YW Transfer Compost SLAS
MSWLF
Closed HHW White Inc in T&P FIRM
MSWLF 1mods
CDLF Tire T&P I Tire Industrial x DEMO SDTF
Collection Mono fill Landfill
'· .. ::/ ·, ,:, . ; .:/\ .
COUNTY: Transylvania ! .
PERMIT NO.: sa-os.
FILE TYPE: COMPLIANCE
Date of Audit: 07 /I 0/02 Date of Last Audit: 05/22/02
FACILITY NAME AND ADDRESS:
RPS Ecusta, Inc.
State Road 1593
Pisgah Forest, NC 28768
FACILITY CONTACT NAME AND PHONE NUMBER:
Mike Cody, Director of Environmental Health and Safety
Telephone: [phone]
FACILITY CONTACT ADDRESS (IF DIFFERENT):
Mike Cody
RPS Ecusta, Inc.
P.O. Box200
Pisgah Forest, NC 28768
AUDIT PARTICIPANTS:
Jim Patterson, N.C. Solid Waste Section
Mike Cody, RPS Ecusta, Inc.
STATUS OF PERMIT:
Active
PURPOSE OF AUDIT:
Inspection of industrial landfill.
NOTICE OF VIOLATION(S) (citation and explanation):
No violations noted.
/ .. ··,, . ., : .. ,
You are hereby advised that, pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $5,000 per day may be assessed for each
violation of the Solid Waste Statute or Regulations. If the violation(s) noted here continue, you may 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.
STATUS OF PAST NOTED VIOLATIONS (List all noted last audit):
NIA
OTHER COMMENTS /SUGGESTIONS:
Trees and bushes have been removed from inactive portions of the landfill. Site looks good.
Page 2 of2
FACILITY COMPLIANCE AUDIT REPORT
Division ofWaste.~nagement ·
. . Solid WasteSection
Please contact me if you have any questions or concerns regarding this audit report.
\....,.-,~~!'.._~~~~~:___(signature) Phone: [phone].
Regional Representative
Distribution: original signed copy to facility --signed copy to compliance officer -e-mail or copy to super
Delivered on : 07 II 5102 by hand delivery x US Mail Certified No. U I '
!
revised 05/23/02 12:32 PM ~A -·;~~ n _, ___ _
NCDENR
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
UNIT TYPE: ( check all that apply to this audit with same Permit number)
Lined LCID YW Transfer Compost SLAS
MSWLF
Closed HHW White lncin T&P FIRM
MSWLF goods
CDLF Tire T&P I Tire Industrial x DEMO SDTF
Collection Monofill Landfill
COUNTY: Transylvania
PERMIT NO.: 88-05
FILE TYPE: COMPLIANCE
Date of Audit: 05/22/02 Date of Last Audit: 02/13/02
FACILITY NAME AND ADDRESS:
RPS Ecusta, Inc.
State Road 1504
Pisgah Forest, NC 28768
FACILITY CONTACT NAME AND PHONE NUMBER:
Mike Cody, Director of Environmental Health and Safety
Telephone: [phone]
FACILITY CONTACT ADDRESS {IF DIFFERENT):
Mike Cody, Director of Environmental Health and
Safety
RSF Ecusta, Inc.
P.O. Box 200
Pisgah Forest, NC 28768
AUDIT PARTICIPANTS:
Jim Patterson, N.C. Solid Waste Section
Mike Cody and Jack Garren, RPS Ecusta, Inc.
ST ATVS OF PERMIT:
Active
PURPOSE OF AUDIT:
Inspection of industrial landfill.
NOTICE OF VIOLATION(S) (citation and explanation):
No violations noted.
You are hereby advised that, pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $5,000 per day may be assessed for each
violation of the Solid Waste Statute or Regulations. If the violation(s) noted here continue, you may 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.
STATUS OF PAST NOTED VIOLATIONS (List all noted last audit):
NIA
OTHER COMMENTS /SUGGESTIONS:
Inactive portions of the landfill are being cleared of vegetation.
Page 2 of2
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
ntact me if you have any questions or concerns regarding this audit report.
Distribution: original signed copy to facility --signed copy to compliance officer -e-mail or copy to super
Delivered on : 05/23/02 by hand delivery x US Mail Certified No. LJ I I i
revised 02/14/02 11 :42 AM E?'A __ •;,6.~
n -.;,~----NCDENR
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
UNIT TYPE: (check all that apply to this audit with same Permit number)
Lined LCID YW Transfer Compost SLAS
MSWLF
Closed IIBW White Incin T&P FIRM
MSWLF Roods
CDLF Tire T&P I Tire Industrial x DEMO SDTF
Collection Mono fill Landfill
Date of Audit: 02/13/02 Date of Last Audit: 11/27/01
FACILITY NAME AND ADDRESS:
RFS Ecusta, Inc.
State Road 1512
Pisgah Forest, NC 28768
FACILITY CONTACT NAME AND PHONE NUMBER:
Mike Cody, Director of Environmental Health and Safety
Telephone: [phone]
FACILITY CONTACT ADDRESS (IF DIFFERENT):
Mike Cody, Director of Environmental Health and
Safety
RFS Ecusta, Inc.
P.O. Box200
Pisgah Forest, NC 28768
AUDIT PARTICIPANTS:
Jim Patterson, N.C. Solid Waste Section
Mike Cody, RFS Ecusta, Inc.
STATUS OF PERMIT:
Active
PURPOSE OF AUDIT:
Semi-annual comprehensive industrial landfill inspection.
NOTICE OF VIOLATION(S) (citation and explanation):
No violations noted.
>·.·
COUNTY: Transylvania ·
PERMIT NO.: 88-05
FILE TYPE: COMPLIANCE
You are hereby advised that, pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $5,000 per day may be assessed for each
violation of the Solid Waste Statute or Regulations. If the violation(s) noted here continue, you may 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.
STATUS OF PAST NOTED VIOLATIONS (List all noted last audit):
NIA
OTHER COMMENTS /SUGGESTIONS:
None
\
Page 2 of2
FACILITY COMPLIANCE AUDIT REPORT
Division of Waste Management
Solid Waste Section
Please contact me if you have any questions or concerns regarding this audit report.
Distribution: original signed copy to facility --signed copy to compliance officer -e-mail or copy to super
Delivered on: 02/15/02 by hand delivery x US Mail Certified No. LJ