9702-20141216INSP

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Wilkes
Closed
MSWLF X HHW White
goods Incin T&P FIRM PERMIT NO.: 97-02
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: December 16, 2014 Date of Last Inspection: May 25, 2011

FACILITY NAME AND ADDRESS:
Dan Johnson Landfill
Lewis Road
Elkin, North Carolina 28621

GPS COORDINATES: N: 36.27050 W: 80.92292

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Kent Brandon, Solid Waste Director
Telephone: [phone] (o) or [phone] (m)
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Post Office Box 389
Roaring River, North Carolina 28669

PARTICIPANTS:
Kent Brandon, Solid Waste Director
David Dillard, Landfill Supervisor

STATUS OF PERMIT:
A Notice of Closure for the Dan Johnson Landfill was issued to Wilkes County on April 16, 1996.

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
N/A

OBSERVED VIOLATIONS

15A North Carolina Administrative Code 13B .0510(c) states: “When a solid waste disposal site has been closed in
accordance with the requirements of the Division, future necessary maintenance and water quality monitoring shall be
the responsibility of the owner and the operator and shall be specified in the closure letter.”
x Post Closure Condition #1 of the Closure Letter dated April 6, 1996 states: “The owner and/or operator shall
take the measures necessary to ensure that the closed site shall continue to meet the design standards for
landfill gas found in Rule .0503(2)(a).
x 15A North Carolina Administrative Code 13B .0503 (2)(a) states: “A site shall meet the following design
requirements:”

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 2

a. The concentration of explosive gases generated by the site shall not exceed:
i. Twenty-five percent of the limit for the gases in site structures (excluding gas controller recover
system components); and
ii. the lower explosive limit for the gases at the property boundary;

Review of methane monitoring records verified that methane gas was recorded above the lower explosive limit for
methane at GP-2, also referred to as BP-2 during the following monitoring events: 4th Quarter 2012 (56.4% Volume),
1st Quarter 2013 (57.5% Volume), 3rd Quarter 2013 (39.0% Volume), 4th Quarter 2013 (51.7% Volume), 1st Quarter
2014 (33.1% Volume), 2nd Quarter 2014 (47.7% Volume), 3rd Quarter 2014 (43.1% Volume), and 4th Quarter 2014
(46.0% Volume). GP-2 is located adjacent to the property boundary on the north side of the site.

Section 5.0 of the approved Landfill Gas Monitoring Plan for the facility requires that within 60-days of detection of
methane levels exceeding the LEL, the County will develop and implement a landfill gas remediation plan for the
combustible gas releases and notify the Division that the plan has been implemented. The plan will describe the nature
and extent of the problem and the proposed remedy. No landfill gas remediation plan has been submitted to the
Division of Waste Management.

By exceeding the lower explosive limit for methane at the property boundary and failing to submit a landfill gas
remediation plan to the Division of Waste Management, Wilkes County is in violation of 15A NCAC 13B .0510(c)
and 15A NCAC 13B .0503(2)(a)(ii).

To achieve compliance, a landfill gas remediation plan must be submitted to the Division Waste Management, Solid
Waste Section within 30-days of receipt of this report and accompanying Notice of Violation describing the nature and
extent of the methane gas releases and a proposed remedy. The plan must be implemented within 60-days of receipt of
this report and accompanying Notice of Violation. The Division of Waste Management, Solid Waste Section, must be
notified immediately afterward, in writing, that the plan has been implemented. Additional measures may be required
by the Division. The landfill gas remediation plan must be submitted to:

Ervin Lane, Hydrogeologist
Division of Waste Management – Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 27699

ADDITIONAL COMMENTS

1. The facility ceased operation as of July 1, 1993.
2. A gate was located at the entrance to site to prevent unauthorized access.
3. The landfill was stabilized with native vegetation. Patches of tall brush were scattered across the landfill. Areas
of dense brush should be cut back and maintained to allow for a thorough inspection of the landfill.
4. Cattle are allowed to graze the landfill area. Please monitor the landfill cap for signs of erosion caused by cattle
grazing and repair any areas of damage as necessary.
5. An area of dense brush and trees were observed on the south side of the landfill adjacent to a deer stand.
However, it was not clear if the trees were located on the landfill cap, or if they were just beyond the footprint of
the landfill. Trees should be discouraged from growing on the landfill. It is recommended that this area be
examined to determine if the trees in this area are indeed on the landfill cap. If so, they should be removed and
the area stabilized with a groundcover sufficient to restrain erosion.
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 3 of 3

6. Edge waste markers consisting of steel T-posts were in place at the time of inspection.
7. No areas of significant settling were observed.
8. A Landfill Gas Monitoring Plan was submitted to the Solid Waste Section on July 11, 2012 and approved on
July 18, 2012. This plan proposed the installation of three (3) landfill gas monitoring wells (GW-1, GW-2, and
GW-3). A document entitled Installation of Landfill Gas Monitoring Probes was submitted to the Solid Waste
Section by Joyce Engineering on November 8, 2012. This document verified the installation of methane
monitoring probes GP-1, GP-2, and GP-3.
x Previous methane monitoring records from 1st, 2nd, and 3rd Quarter 2013 referenced exceedences at
GP-2 while the summary chart referenced BP-1, BP-2, and BP-3.
x The monitoring report for 1st Quarter 2014 referred to an exceedence of methane above the LEL at
BP-2. However, records for 2nd, 3rd, and 4th Quarter reports for 2014 referred to exceedences of
methane above the LEL at GP-2.
x Please continue to ensure that all future methane monitoring reports continue to provide the
proper designation and label for all methane probes monitored during each event. Labels must
be consistent with the descriptions detailed in the document entitled Installation of Landfill Gas
Monitoring Probes submitted by Joyce Engineering and dated November 8, 2012.
9. Semi-annual groundwater monitoring was being performed. Records for 1st and 2nd semi-annual sampling for
2012, 1st and 2nd semi-annual sampling for 2013 and 1st semi-annual sampling for 2014 were verified.
10. During the inspection GP-1, GP-2, and GP-3 were found to be locked and labeled. All three monitoring probes
were protected by barbed wire fence attached to four steel posts.
11. During the inspection, three apparent groundwater monitoring wells were observed.
x A well located on the west side of the landfill was observed which was locked, but a label was
needed.
x A well located at the southeast corner of the site was observed which was locked, but a label was
needed. The door to the exterior casing also did not appear to completely close. This condition
should be repaired.
x A monitoring well was observed between GP-1 and GP-2. A lock was located on the door of the
outer steel casing, but the hinge was damaged. This condition should be repaired. A label is also
needed.

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

___________________________ Phone: [phone]
Charles T. Gerstell
Environmental Senior Specialist
Regional Representative

Sent on: 1/20/15 Email Hand delivery X US Mail Certified No. [7011 3500 0000
4267 1535] Kent Brandon

Copies: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Sarah M. Rice, Compliance Officer

John Yates, Wilkes County Manager Certified Number: 7011 3500 0000 4267 1528
110 North Street
Wilkesboro, North Carolina 28697

Digitally signed by Charles Gerstell
DN: cn=Charles Gerstell, o=DENR,
ou=Solid Waste Section,
email=[e-mail]
v, c=US
Date: 2015.01.20 10:22:51 -05'00'