3801_ROSCANS_1993

f
STAT£ y
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina. 27604
James B. Hunt, Jr., Governor Division of Solid Waste Management
Telephone (919)T33-0692 Jonathan B. Howes, Secretary
July 15, 1993
Ms. Patsy Irons
County Manager, Graham County
P.O. Box 575
Robbinsville, N.C. 28771
Re: Implementation Of Subtitle 'D' Ground -water Monitoring Program
Dear Ms. Irons,
The purpose of this correspondence is to provide information and
clarification on the changes in ground -water monitoring requirements
for MSWLF facilities that remain in operation after October 9, 1993.
The proposed North Carolina Solid Waste Management Rules reflect
significant changes for ground -water monitoring based on requirements
of the E.P.A. Subtitle D Rules.
Attachment A to this letter provides a summary of important
dates and significant activities that must be accomplished in order
to be in compliance with the new rules. Attachment B contrasts
existing and proposed ground -water monitoring and assessment
requirements based on changes in the rules. Because of significant
increases in costs that will be incurred in order to operate a MSWLF
under the new Subtitle D Rules, including financial assurance and
increased costs for ground -water monitoring and assessment, you may
wish to seriously consider closing your sanitary landfill prior to
October 9,1993, when the new rules become effective.
Based on past ground -water monitoring data for the Graham County
landfill, there is evidence from indicator parameters of possible
violations of North Carolina Groundwater Quality Standards at some of
the detection monitoring wells. A copy of your most recent sampling
analytical data is attached on which highlighting has been done for
the elevated indicator parameters. When the new rules take effect
and further sampling has been performed Graham County may be required
to implement assessment monitoring for all Appendix II constituents.
Since the Groundwater Quality Standards are also used in establishing
the ground -water protection standards, you may also rapidly move into
assessment of corrective action alternatives based on a full-scale
P.O. Ik>x 27687, Puleigh, North Carolina 27611-7687 Telephone [phone] rax d 90-733-0513
An rgiuil OpIx,rnutity Affirmative &-tion rmpluyer

Page 2
ground -water investigation to determine the nature and extent of
contamination at the site.
If Graham County chooses to continue to operate their MSWLF
facility after October 9, 1993, then you need to begin planning and
budgeting immediately for the activities outlined in Attachment A. A
revised Water Quality Monitoring Plan must be submitted as part of
the Transition Plan on or before April 9, 1994. Additional
monitoring wells will be necessary to upgrade the present monitoring
system to meet the requirements of the new N.C. Solid Waste
Management Rules for MSWLF units. All background sampling and
related activities for the upgraded monitoring system must be
completed and reported to the Division in order to demonstrate
compliance with the new water quality monitoring requirements on or
before October 9, 1994.
Please note that the goals and objectives for ground -water
assessment monitoring and ground -water contamination investigations
are the same under both the current and the proposed rules and shall
be accomplished in a way that is protective of human health and the
environment. However, current rules allow for greater flexibility in
the assessment and investigation activities and the sample analytical
costs could be substantially less using the constituent list required
under current rules and policy as compared to analytical costs
required by the new rules based on Subtitle D, which require sampling
for the Appendix II list of constituents.
I hope this letter has been helpful in providing you more
insight into the actions that will be required by Graham County to
maintain compliance with the water quality monitoring requirements of
the Solid Waste Management Rules as we make the transition to the new
rules growing out of the E.P.A. Subtitle D Regulations. If you have
any questions or comments regarding this letter, please contact the
Solid Waste Section at [phone].
Sincerely,
&4Y I
Bobby Lutfy, Hydrogeologist
Solid Waste Section
cc: James Patterson
Attachments

NC DEPARTMENT OF E_.IRONMENT, HEALTH AND NATU1 _" RESOURCES
Division of Solid Waste Management
Solid Waste Section
SOLID WASTE NANAGE ENT FACILITY EVALUATION REPORT
Type of Facility Permit # county
Name of Facility. Location
Date of Last Evaluation
I_ Pertiit Conditions Followed Yes No N/A
A. Specific Condition(s) Violated
II. Operational Requirements Followed Yes No
15A N.C_ Admin. Code 13B Section
A_ Specific Violation(s) by number and letter.
Lw.
E.
III. Other Violations of Rule or Law
IV. Evaluator's Comments
V. Continuation Page Required? Yes No Receiving Si
Evaluation Date Solid Waste Section
DENNR 3793 (Part I White: Facility Part II Canary_ Central Office Part III Pink: Regional Office)
Solid Waste Section (Review 7/94)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid Waste Section
SOLID WASTE KANAGENENT FACILITY EVALUATION REPORT
Type of Facility 1 Perini t # 6 County.
L 4 Ac,
J
-ILL -----
Name of Facility Cn.(Z.Alu Location
Date of Last Evaluation
I. Permit Conditions Followed Yes No N/A
A. Specific Condition(s) Violated
11. Operational Requirements Followed Yes Y No
15A N.C_ Admin. Code 138 Section o 11 'S 0 E;
A. Specific Violation(s) by number and Letter.
S4 I' ell) 1(c). /cr,
III. other Violations of Rule or Law
IV. Evaluator's Comments
CO.
\,,Of
V. Continuation Page Required? -Yes No Receiving Signature JT�, Y(ud if­nr 5
Evaluation Date Solid Waste Section
DEHNR 3793 (Part I (hite: Facility Part II Canary: Centro"Office Part III Pink: Regional Office)
Solid Waste Section (Review 7/94)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste management
Solid Waste Section
SOLID WASTE MANAGEMENT FACILITY EVALUATION REPORT
Type of Faci I i ty Permit # 39 — County
Name of Facility (2.unn "JV1j Location I I'L U )r5y;
Date of Last Evaluation
I. Permit Conditions Followed Yes No N/A
A- Specific Condition(s) Vio
II. Operational Requirements Followed Yes No
15A N.C_ Admin. Code 138 Section - 05 0!5
A. Specific Violation(s) by number and Letter.
cocXICA
C,
6 01 , C v. A, 9 -4-.k 1 5 jej J.h /A
III. Other Violations of Rule or Law
IV. Evaluator's Comments
V. Continuation Page Required? —Yes No Receiving Signature&
Evaluation Date Solid Waste Sec DEHNR 3793 (Part I White: Facility Part II Canary: Cen fal Office Part III Pink- Regional Office)
Solid Waste Section (Review 7/94)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid Waste Management
Solid Waste Section
J SOLID WASTE NAMAGEIENT FACILITY EVALUATION REPORT
Type of Facility �r lwr�{ / %� Permit #, ( County /`� pm
� 4 f
Name of Facility. ! 7t1 1, -2't Location i �V,�i7/f3s
�P
Date of Last Evaluation
I_ Permit Conditions Followed /.`"Yes No N/A
d`,
A. Specific Condition(s) Violated
II. Operational Requirements Followed Yes No
15A N.C. Admin. Code 130 Section a 0 — o' 4�
A. Specific Violation(s) by rxsber and Letter-
.
III_ Other Violations of Rule or Law
IV. Evaluator's Comments bs ( lt')yA-Z
s
V. Continuation Page Required? Yes _A'_No Receiving Signature
i
Evaluation Date s ") n 1 Solid Waste Section
DEHNR 3793 (Part I White: Facility Part II Canary: Central Office
Solid Waste Section (Review 7/94)
Part III Pink: Regional Office)

NC DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Solid waste Management
Solid waste Section
SOLID WASTE MANAGEMENT FACILITY EVALUATION REPORT
Type of Facility MhthrrI. �i+(i��/%/ Permit * ..3 b County �2 14:1
Name of Facility / 2 L1,a'j bj4 rst .)1 � — -AM4 Location
Date of Last Evaluation f__ ,D
I. Permit Conditions Followed
A. Specific Condition(s) Vio
.----Yes No N/A
II. Operational Requirements Followed Yes No
15A N.C. "in. Code 138 Section
A. Specific Violation(s) by number and letter.
III. Other Violations of Rule or Law
IV. Evaluator's Conments�F *T naeiy jl;i 1irol r 5 1)Lsi,a, a 0 >�G1csS C.
V. Continuation Page Required? Yes li No Receiving Signature
Evaluation Date Solid waste Section
DEHNR 3793 (Part I white: Facility Part II Canary: Centrl) Office Part III Pink: Regional office)
Solid waste Section (Review 7/94)

Gra4atn TountV Nourb of TountV Tommiosionero
William Hall Jenkins
Chairman
Ralph L. Crisp
Vice -Chairman
Raymond Williams
Member
N.C. Department
of Environment, Health
and Natural Resources
Attn: James Patterson
59 Woodfin Place
Asheville, N.C. 28801
Dear Mr. Patterson:
P.O. Box 575
Robbinsuille, NC 28771
[phone]
November 22, 1993
Pat S. Irons
County Manager
Leonard Lloyd
County Attorney
Janet Lequire
County Clerk
Thank you for your visit of 10/27 and 11/10/93. Our discussion related
to consolidation of green box locations was very informative.
On your evaluation report of 11/10/93, you stated windblown material
needed to be removed. I have assigned a community service worker who
has 200 hours, to this task.
Again thank you for your assistance to Graham County.
jl
Sincerely yours,
Pat S. Irons, Manager
County ofGrah.am
"Graham County Pride"

Gra4am TountV Nourd of TountV Tommissioners
William Hall Jenkins
Chairman
Ralph L. Crisp
Vice -Chairman
Raymond Williams
Member
North Carolina Department
of Environment, Health and
Natural Resources
Attn: James Patterson
59 Woodfin Place
Asheville, N.C. 28801
Dear Mr. Patterson:
P.O. Box 575
Robbinsuille, NC 28771
[phone]
October 07, 1993
Pat S. Irons
County Manager
Leonard Lloyd
County Attorney
Janet Lequire
County Clerk
I would like to express my appreciation to you for coming by the office to update
me on current Subtitle "D" regulations.
Our discussion on various problems and solutions was very helpful. This will
insure compliance and avoid unnecessary delays.
The Commissioners from the tri-county area will meet October 12th to discuss
future plans and strategy.
Again thank you for your assistance.
cc: James Coffey, Supt.
Sincerely yours,
Pat S. Irons, Manager
County of Graham
"Graham County Pride"

OPERATION/CONSTRUCTION MANAGERS
Municipal
Services
P.O. Box 97, Gamer, North Carolina 27529 [phone]
September 29, 1993
Mr. James Coffey, Supervisor
NC DEHNR
Solid Waste Management Section
Pv Box 27687
Raleigh, NC 27611-7687
Re: Closure of Graham County Landfill
Dear Jim:
CIVIUSANITARY ENGINEERS
Engineering
Company, P.A.
O. Box 349, Boone, North Carolina 28607 (704)262-1
I am writing in behalf of Graham County concerning the closure of their existing landfill.
Graham. County will transfer their waste by direct haul to the Cherokee County Regional
Landfill by the commercial and County haulers who presently serve Graham County. The
local residents who do not have commercial pickup will be allowed to use the green boxes
which are located throughout the County.
Graham County will stop receiving waste by October 9, 1993 unless the six-month
extension is granted. If the extension is granted for landfills that receive less than 100 tons
per day, Graham County will stop receiving waste by April 9, 1994.
If you have any questions or need additional information, please do not hesitate to call.
Very truly yours,
/MUNICIPAL ENGINEERING SERVICES CO., PA
-- ' '
D. Wayne Sullivan
DWS:cw
Copy: Ms. Pat Irons, Manager
Graham County

Gra4atn Tountu Nourd of TountU Tommiooionero
William Hall Jenkins
Chairman
Ralph L. Crisp
Vice -Chairman
Raymond Williams
Member
P.O. Box 575
Robbinsuille, NC 28771
[phone]
August 27, 1993
North Carolina Department
of Environment, Health and
Natural Resources
Attn: James Patterson
59 Woodfin Place
Asheville, N.C. 28801
Pat S. Irons
County Manager
Leonard Lloyd
County Attorney
Janet Lequire
County Clerk
Dear Mr. Patterson:
I would like to take this opportunity to personally thank you for tak-
ing the time to come by and discuss the new Subtitle "D" regulations.
The Commissioners and I are most appreciative for your assistance with
the necessary permitting required in order for Graham County to comply
with all regulations prior to October 09, 1993.
Again, thank you for your time and assistance.
jl
cc: James Coffey
Sincerely,
Pat S. Irons, Manager
County of Graham
"Graham County Pride"

W
Gnt4am Touutg Nourd of TountV Tommission ero
William Hall Jenkins
Chairman
Ralph L. Crisp
Vice -Chairman
Raymond Williams
Member
Mr. James Coffey
Solid Waste Section
NC DEHNR
P.O. Box 27687
Raleigh, N.C. 27611
Dear Mr. Coffey:
P.O. Box 575
Robbinsuille, NC 28771
[phone]
August 27, 1993
Pat S. Irons
County Manager
Leonard Lloyd
County Attorney
Janet Lequire
County Clerk
The Graham County Board of County Commissioners would like to express
their appreciation to you and your staff for your assistance with the
pending Subtitle "W' regulations.
The Board respectfully requests a permit be issued to Graham County
to transport their solid waste to the Cherokee County landfill. We
also request assistance in revising Cherokee County's permit in order
to receive same.
Thank you again for your invaluable assistance as we all face Subtitle
"D" compliance regulations.
If further information is required, please advise.
J1
cc James Patterson
Sincerel} Yours,
Hall J A�Chairman
Graham County Board of
County Commissioners
"Graham County Pride"