Gaston Co MSWLF Lead Paint Waste Disposal Followup Notification

August 5, 2013
NCDENR, DWM, Solid Waste Section
Field Operations Branch
2090 US Highway 70
Swannanoa, NC 28778
Attention: Mr. Bill Wagner
Senior Environmental Specialist
Reference: Notification of Disposal of Lead -Based Paint Debris
Gastonia County Municipal Solid Waste Landfill
3155 Philadelphia Church Rd
Dallas, NC 28034-7698
S&ME Project No. 1354-13-101
Dear Mr. Wagner:
As a follow-up to a telephone conversation between you and Mr. Al Quarles of S&ME on
August 1, 2013, S&ME submits this letter as documentation of the disposal of lead -based
paint debris at the Gaston County Landfill. As part of a demolition/renovation project at
the former Loray Mills (1101 West Second Ave, Gastonia, NC 28052), S&ME collected
a composite sample of waste on July 18, 2013. The waste was generated from the
removal of lead -based paint from the 5th floor of main plant building. S&ME hand
delivered the sample to Pace Analytical Laboratory for the analysis of lead (EPA Method
6010/3010), following TCLP extraction (EPA Method 1311), to determine if the waste
would be classified as a hazardous waste (lead concentration 5 milligrams per liter or
greater). The results were reported to S&ME on July 24, 2013, with a lead concentration
of <0.025 mgfL. S&ME provided the laboratory report to S&ME's client and their
general contractor, who in turn disposed of most of the waste (19.28 tons) off -site as a
non -hazardous, non -special waste at the Gaston County Landfill on July 30 and 31, 2013.
Gaston County approved the disposal of the waste based on the laboratory results.
On July 31, 2013 (11:37am), Mr_ Korey Drew of Pace called Mr. Quarles and informed
Mr. Quarles that the laboratory swapped our sample with another sample (after the TCLP
extraction), and this error was discovered during an internal audit. Pace submitted a
revised report on July 31, 2013 via email to Mr. Quarles (received 11:44am on July 31,
2013). The lead concentration was reported as 16.3 mg/L.
S&ME subsequently contacted S&ME's client, the client's contractors, Gaston County
Landfill, and the NCDENR Hazardous Waste and Solid Waste Section of the incident.
S&ME requested that no additional waste material be taken from the project site. S&ME
S&ME, INC. 1 9751 Southern Pine Boulevard J Charlotte, INC 28273-5560 J p 704.523.4726 f 704.525.3953 J www.smeinc.com

Notification of Disposal of Lead -Based Paint Debris August 5, 2413
Gastonia County Municipal Solid Waste Landfill S&ME Pro'ect No. 1354-13-101
also requested that the landfill fax the weigh tickets of the waste delivered by the
contractor disposing of the waste.
On August 1, 2013, S&ME received four weight tickets indicating that four loads of the
lead -based paint debris waste (two on July 30 and two on July 31) totaling 19.28 tons,
was accepted by the landfill. S&ME contacted Ms. Marcie Smith with Gaston County
Landfill to 1) ask if the disposal location of the lead -based paint debris could accurately
be located, and 2) to see if the area of the waste disposal could be secured to prevent
additional waste being placed over that area. Ms. Smith discussed this with the landfill
operations staff and determined that the location is known, and had the disposal location
staked and the general area of the landfill secured to prevent additional waste placed in
the area. Ms. Smith indicated that the landfill is able to use another area for general
waste disposal.
At 1:30pm on August 1, 2013, Mike Cashio and Al Quarles of S&ME met at the landfill
with Ms. Smith and Barry Cloninger with the Gaston County Landfill, and Ms. Cheryl
Johnson with Pace to discuss the incident, to view the area of disposal, and to discuss
how the issue can be resolved. The above named individuals visited the disposal area and
took pictures. Ms. Smith indicated that, as waste is placed, they push the waste forward
to the slope of the waste with little lateral spreading. The two days of waste resulted in a
layer approximately five feet thick over an estimated area 20 feet wide by 50 feet long.
On August 2, 2013, Mr. Cashio and Mr. Quarles met with Mr. Greg Whitman and Ms.
Felicia Grogan with Pace to discuss the project. Pace is planning to manage the removal
of the waste with assistance from A&D Environmental, and will coordinate the planned
actions with the Gaston County Landfill and the NCDENR (Solid and Hazardous Waste
Sections). S&ME plans to observe the removal actions.
If you have any questions concerning this letter or need additional information at this
time, please contact us at your convenience.
Regards,
S&ME, Inc.
Al qkdarles, L.G.
Senior Hydrogeologist
C. Mi e Cas 1o, Jr., CIH
Manager, EHS Services
c: Mr. Greg Whitman, Pace Analytical Services, Inc.
Ms. Marcie Smith, Gaston County Landfill
Mr. Sean Morris, NCDENR, DWM, Hazardous Waste Section
Mr. John Gumpert, Loray Mills Redevelopment LLC
WAQlwaq: CMC