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1'
FACILITY COMPLIANCE INSPECTION REPORT
--Division of Waste Management
NCDENR Solid Waste Section
NORTH CAROLINA DEPARTMENT OF 4
ENVIRONMENT AND NR RAL RESOURCES
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: Graham
MSWLF
PERMIT NO.: 38-01
Closed
X
HI-IW
White
Incin
T&P
FU M
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: February 21, 2012 Date of Last Inspection: May 19, 2009
FACILITY NAME AND ADDRESS:
Graham County Municipal Solid Waste Landfill
Atoah Road
Robbinsville, N. C. 28771
GPS COORDINATES: N: 35.27452 E:-83.84299
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Donnie Orr, Director, Graham County Sanitation Department
Telephone: 828-479-9369
FACILITY CONTACT ADDRESS:
12 North Main Street
Robbinsville, NC 28771
PARTICIPANTS:
Troy Harrison- NCDENR/DWM/Solid Waste Section
Donnie Orr, Graham County
STATUS OF PERMIT:
Closure letter issued for Permit No. 38-01 issued on January 30, 1996.
The letter contains post closure conditions for the landfill.
An amendment was issued on January 8, 2002.
PURPOSE OF SITE VISIT:
Comprehensive Audit of Closed MSW Landfill
STATUS OF PAST NOTED VIOLATIONS:
All past violations have been resolved.
OBSERVED VIOLATIONS
1. 15A North Carolina Administrative Code 13B .0510 (c) requires that "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."
The January 30, 1996 closure letter, in the POST CLOSURE CONDITIONS section item #1 (Management of
Landfill Gas), 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)."
15A NCAC 13B .0503(2)(a) states: "A site shall meet the following design requirements:
—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 control or recovery system
components); and
(ii) the lower explosive limit for the gases at the property boundary."
There are no records that show that explosive gas monitoring has been conducted at the closed landfill as
required in the closure letter.
In order to achieve compliance with 15A NCAC 13B .0510(c), within 90 days of receiving this report,
Graham County must provide evidence that explosive gas monitoring has been performed as required in the
closure letter, or submit a new permanent monitoring explosive monitoring plan to the Solid Waste Section
for approval. The plan should satisfy all conditions of Rule 15A NCAC 13B .0503(2)(a)(i) and (ii). Please
submit copies of the methane monitoring plan to
Elizabeth Werner; Solid Waste Section Hydrogeologist
Division of Waste Management, Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina, 27699-1646
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 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.
ADDITIONAL COMMENTS
1. All photographs were taken by Troy Harrison on February 21, 2012.
2. The Landfill ceased operations on April 8, 1994. The property that the landfill is located on is owned by the
US Forest Service.
3. The entrance to the landfill was secured by a locked gate.
The three groundwater monitoring wells were observed. None of the wells were'secured. 15A NCAC
02C .0108 (k) requires that "all non -water supply wells, including temporary wells, shall be secured with
a locking well cap to ensure against unauthorized access and use." The security of the wells was also
mentioned in the March 17, 2009 audit. As a reminder, the results of the most recent groundwater
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 3
4. The cap of the landfill had not been mowed in quite sometime and briers were starting to appear. In
addition, it is unclear where waste was deposited at the landfill. There were also trees in areas that
could be growing over waste. Graham County needs to clearly locate and permanently mark the edge
Top of landfill possible woody vegetation over waste
Please contact me if you have any questions or concerns regarding this inspection report.
828-296-4701
Phone:
Environmental Senior Specialist
Reninnal Renre.eentativv
Sent on: March 8, 2012 Email Hand delivery US Mail X Certified No. 7006 2150 0005 2458 9747
Copies: Jason Watkins, Western District Supervisor
Mark Poindexter, Field Operations Branch Head
Shawn Mckee, Solid Waste Section
Kim Crisp, Assistant County Manager
Elizabeth Werner, DWM Hydrogeologist
Landon Davidson, DWQ/Aquifer Protection
2
INSTRUMENT CALIBRATION REPORT
Pine Environmental Services, Inc.
8411 Garvey Drive, Suite 113
Raleigh, NC 27614
Toll -free: (866) 646-PINE (7463)
Pine Environmental Services, Inc.
Instrument ID 7224
Description Gem 2000
Calibrated 5/4/2012
Calibration Result Calibration Successful
Who Calibrated Andrew Briley
All instruments are calibrated by Pine Environmental Services, Inc. according to the manufacturer's
specifications, but it is the customer's responsibility to calibrate and maintain this unit in accordance with the
manufacturer's specifications and/or the customer's own specific needs.
Notify Pine Environmental Services, Inc. of any defect within 24 hours of receipt of equipment
Please call 866-960-7463 for Technical Assistance
Pine Environmental Services, Inc., Windsor Industrial Park, 92 North Main Street, Bldg 20, Windsor, NJ 08561, 800-301-9663
www.pine-environmental.com
Landfill Gas Migration Monitoring Report
Prepared for
Graham County Closed Unlined MSWLF
Robbinsville, North Carolina
May 2012
Permit Number: 38-01
MESCO Project Number: G11038.0
Reported on May 17, 2012
Performed on May 8, 2012 i Municipal Engineering
savloes �/'"� C—p y,ra.
Garvey NC f Bawy NC
Municipal Engineering Services Company, P.A.
Garner and Boone, North Carolina
License No. C-0281
CIVIL/SANITARY/ENVIRONMENTAL ENGINEERS
Municipal
Services
SITE PLANNING/SUBDIVISIONS
Ms. Elizabeth Werner
Solid Waste Section Hydrogeologist
Division of Waste Management, SWS
1646 Mail Service Center
Raleigh, NC 27699-1646
Phone: (919) 508-8496
Email: elizabeth.wernerancdenr.eov
SOLID WASTE MANAGEMENT
Engineering
Company, P.A.
SUBSURFACE UTILITY ENGINEERING (SUE)
May 17, 2012
Re: Landfill Gas Migration Monitoring Report
Graham County Inactive Closed MSWLF
Permit Number: 38-01
Dear Ms. Werner:
Introduction
In response to a Notice of Deficiency issued by the Solid Waste Section on March 8, 2012 this report is intended to
provide evidence that explosive gas monitoring has been performed and methane has not been detected thus the
facility meets the design standards for landfill gas found in Rule .0503(2)(a)(i)(ii).
A landfill gas (LFG) migration monitoring network was installed at the Inactive Closed Graham County MSWLF-
(38-01) by Municipal Engineering Services Company, P.A. (MESCO) personnel on May 7, 2012. The facility is
very rural, located upon gated property owned by the US Forest Service, sits atop a mountain and is surrounded by
streams which effectively mitigates potential risk of exposure to LFG migration. The LFG monitoring system
consists of six LFG monitoring probes surrounding the perimeter of the waste. MESCO personnel recorded LFG
levels from the monitoring system on May 8, 2012. This report contains a description of the monitoring network,
monitoring procedures, summary of monitoring results, and findings. A site areal photographic depicting
monitoring locations, a schematic of the methane probes, instrument calibration certificate, and a tabulation of
recorded LFG levels are also attached.
Methane Monitoring Network
Six LFG probes were installed surrounding the perimeter of the closed landfill to monitor LFG gas levels migrating
through soil. The number and location of probes were based upon several factors such as proximity of off -site
structures, subsurface soil stratigraphy, and hydrogeological barriers. Structures are not located on the landfill
facility and the closest identified potential off -site structure is located over 1,000 linear feet, 280 vertical feet
separation and beyond a perennial hydrogeologic barrier from the bottom of the waste boundary. A site aerial
photograph depicting the monitoring system is attached as Figure 1.
The methane probes were constructed by a NC -Certified Well Contractor (NCWC-3301-A) and consisted of 3/4
inch PVC screen and riser pipe. The probes were installed in a borehole with a filter pack around the screen and a
bentonite then concrete seal over the filter. The methane probes are equipped with a ball valve and barb fitting to
facilitate connecting a gas monitoring instrument to accurately measure potentially accumulated landfill gas. A
schematic detail of the methane probes are presented in attached Figure 1.
PO Box 97, Garner, North Carolina 27529 (919) 772-5393 PO Box 349, Boone, NC 28607 (828) 262-1767
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Monitoring Procedures
MESCO personnel performed LFG migration monitoring of the network on May 8, 2012. Monitoring was
performed in accordance with procedures outlined in the NCDENR Solid Waste Section Landfill Gas Monitoring
Cmidance Document dated November 2010 utilizing a properly approved/calibrated GEM 2000 analyzer (calibration
certificate attached). LFG readings were taken from 6 LFG probes (M2-1 through MP-6) in the afternoon, and
during a period of falling barometric pressure which are considered optimum conditions for detection of methane
migrating from a landfill.
Monitoring Results
Detectable concentrations of methane was not detected in any of the probe locations. LFG readings are presented in
the attached Landfill Gas Monitoring Data Form.
Findings
The LFG migration monitoring system as implemented is expected to sufficiently detect LFG migration through the
soil around the perimeter of the landfill. Methane gas was not found to be migrating from the landfill in
concentrations in exceedance of the applicable regulations during the May 8, 2012 event. There appears to be no
evidence to suggest that any receptors are at risk from potential methane migration at this time.
Closing
If you have any questions regarding this report or any facet of the monitoring system please contact us by phone at
(919) 772-5393 or by email at jpfohl c,mesco.com.
Sincerely,
MUNICIPAL ENGINEERING SERVICES CO., P.A.
Jonathan Pfohl
Environmental Specialist
Enclosures
cc: Ms. Kim Crisp
Graham County
Mr. Troy Harrison
Solid Waste Section
INSTRUMENT CALIBRATION REPORT
Pine Environmental Services, Inc.
8411 Garvey Drive, Suite 113
Raleigh, NC 27614
Toll -free: (866) 646-PINE (7463)
Pine Environmental Services, Inc.
Instrument ID 7224
Description Gem 2000
Calibrated 5/4/2012
Manufacturer CES Landtec
State Certified
Model Number GEM2000
Status Pass
Serial Number/ Lot gm08O87105
Temp °C 22
Number
Location North Carolina
Humidity % 50
Department
Calibration Specifications
Group # 1
Range Ace %
0.0000
Group Name Methane
Reading Ace %
3.0000
Stated Accy Pct of Reading
Plus/Minus
0.00
Nom In Val / In Val In Type Out Val
Out Type
Fnd As
Lft As
Dev%
Pass/Fail
15.00 / 15.00 %Volume 15.00
-----------------------
%Volume
---------------------
15.00
---------------------------------------------------------------------
15.00
0.00%
Pass
-------------------------------------- ------------------ ------
Group # 2
Range Ace %
0.0000
Group Name Carbon Dioxide
Reading Ace %
3.0000
Stated Accy Pet of Reading
Plus/Minus
0.00
Nom In Val / In Val In Type Out Val
Out Type
Fnd As
Lft As
Dev%
Pass/Fail
15.00 / 15.00 %Volume 15.00
%Volume
15.00
15.00
0.00%
Pass
------------------ -------------------------------------------------------------------------------------------------------------------------------------------------------------------
Group # 3
Range Ace %
0.0000
Group Name Oxygen
Reading Ace %
3.0000
Stated Accy Pct of Reading
Plus/Minus
0.00
Nom In Val / In Val In Type Out Val
Out Type
Fnd As
Lft As
Dev%
Pass/Fail
20.90 / 20.90 % 20.90
%
20.90
20.90
0.00%
Pass
Test Instruments Used During the Calibration
Test Standard ID Description Manufacturer
(As Of Cal Entry Date)
Serial Number / Next Cal Date /
Model Number Lot Number Last Cal Date/ Expiration Date
Opened Date
NC 15% CH4 NC 15% ch4 15% co2 Spec Air GP12100 Lot 012040 4/30/2013
15% CO2 (Lot 012040)
NC ZERO AIR NC Zero Air Spec Air GP 12510 052209 5/22/2012
LOT 052209
Notes about this calibration
Pine Environmental Services, Inc., Windsor Industrial Park, 92 North Main Street, Bldg 20, Windsor, NJ 08561, 800-301-9663
www.pine-enviromnental.com
NC Division of Waste Management — Solid Waste Section
Landfill Gas Monitoring Data Form
Notice:This form and any information attached to it are "Public Records" as defined in NC General Statute 132-1. As such, these documents
are available for inspection and examination by any person upon request (NC General Statute 132-6).
Facility Name: Graham Co. Closed MSWLF Permit Number: 38-01
Date of Sampling: 05/08/12 NC Landfill Rule (.0500 or .1600): 0.0500
Name & Position of Sample Collector: Jonathan Pfohl (MESCO Env. Specialist)
Type & Serial Number of Gas Meter: GEM 2000 (GM08087105 Pine) Calibration Date of Gas Meter: 05/04/12
Date & Time of Field Calibration: 5/8/12 9 AM OK
Type of Field Calibration Gas (15/15 or 35/50):
Pump Rate of Gas Meter: 300 cc/min
Ambient Air Temperature: 68 F
15/15 Expiration Date of Field Calibration Gas Canister: 04/30/13
Barometric Pressure: 27.02" Hg General Weather Conditions: Partly Cloudy
Instructions: Under "Location or LFG Well" identify the monitoring wells or describe the location for other tests (e.g., inside buildings). A
drawing showing the location of test must be attached. Report methane readings in both %LEL and % methane by volume. A reading in
percent methane by volume can be converted to %LEL as follows: % methane by volume = %LEU20
Location or
LFG Well ID
Sample
Tube
Purge
Time
Reading
Taken
Time
Pumped in
Seconds
Initial %
LEL
Stabilized
% LEL
% CH4 by
Volume
% 02
% CO2
Notes
Background
200
12:00 PM
250
0
0
0
20.8
0
Ambient Downwind of MSWLF
MP-1
200
02:50 PM
250
0
0
0
16.2
0.1
MP-2
200
02:36 PM
250
0
0
0
19.2
0.2
MP-3
200
02:15 PM
250
0
0
0
15.7
1.1
MP-4
200
01:55 PM
250
0
0
0
16.7
0.2
MP-5
200
12:31 PM
250
0
0
0
16.5
0.1
MP-6
200
12:18 PM
250
0
0
0
15.5
1.3
Background
200
03:05 PM
250
0
0
0
20.8
0
Ambient Downwind of MSWLF
na = Not Available
Baseline = Ambient Air Sample At Facility
Standard at property line 100% LEL, 5% By Volume, 50,000 PPM of Methane
Certification
To the best of my knowledge, the information reported and statements made on this data submittal and
attachments are true and correct. I am aware that there are significant penalties for making any
false statement, representation, or certification including the possibility of a fine and imprisonment.
SIGNATURE
Environmental Specialist (MESCO)
TITLE
FMA
--AVA
NCDEENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
March 8, 2012
CERTIFIED MAIL 7006 2150 0005 2458 9747
RETURN RECEIPT REQUESTED
Kim Crisp — Graham Co. Assistant Manager
12 North Main St.
Robbinsville, NC 28771
SUBJECT: Notice of Deficiency
Compliance Inspection Report
Closed Graham County MSW Landfill
Permit No.: 38-01
Graham County
Dear Ms. Crisp,
Dee Freeman
Secretary
On February 21,, 2012, Troy Harrison representing the State of North Carolina, Division of
Waste Management Solid Waste Section ("Section'), inspected the above referenced facility for
compliance with North Carolina Solid Waste Statues and Rules. Donnie Orr was present.
representing the Graham County Sanitation Department. During this inspection, the following
items were noted and/or observed:
A. 15A NCAC 13B .1604(b)(2)(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. "
The January 30, 1996 closure letter, in the POST CLOSURE CONDITIONS section
item #1 (Management of Landfill Gas), 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)."
15A NCAC 13B .0503(2)(a) states: "A site shall meet the following design
requirements:
(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 control
or recovery system components), and
1601 Mail Service Center, Raleigh, North Carolina 27699-1601 One
Phone: 919-707.8600 \ Internet: www.ncdenr.gov NO thC/arff
olllin
An Equal Opportunity' Affirmative Action Employer — 50010 Recycled 110% Post Consumer Paper Nat `a i
There are no records that show that explosive gas monitoring has been conducted. of
the closed landfill as required in the closure lefter
Within 90 days from receipt of this Notice, the ifaellify must complete the following:
"Corxectrve Actions"
Graham County mustprovide evidence that_explosive gas monitoring has been -performed as required: in
the closure letter, or subnriit anew permanent monitoring explosive monitoring plan tc� the Solid Waste,.
`Section forapproval. The plan should satisfy all conditions of Rule 15A NCAC O .0503(2)(a)(i) and-
00} Please submit copies of the methane monitoring plan'to.
Elizabeth Werner; Solid Waste Section. Hydrogeologist
Division of %00vMana ;ement, Solicl Waste Section
1646`Mail'9ervice Center
RaleEgh,'North:Garolnia,;27699 64:6
Failure to comply with this.schedule may subject the=facility and/or all responsible parties to
enforcement=actions including a notice of vialation, civil penalty, injunction from operation of a
solid waste in anagement.facility or a solid waste collection service. -and anysuch-any ief�as
mad benecessary to `achieve compliance `with the North Carczlina Solid Waste Ivlariagerrent Act
and Rules. Pursuant to N G G S . 130A. 22(a):ar d 1 SA NCAt✓ 13B, Q101 47Q7, an
adnArd afive penalty of up to $15,000,00 per d�.y may by assessed for each of*
violation
Solid Waste Laws, Regulations; Conditions of -a or an Order -issued under Article'9 of
Chapter 130.A. of the N C GenetdLstatutes.
if you lave axy questions, please c_ ontactme at (828)96 470I ore -mail at
gMharrison@rfe-dear. o
ec Mark Poindexter, Field. Operations Branch Supervisor Solid Waste_ Section
Jason Watkins* Western Distract Supervisor—.S.Q1id Waste Section:
�havm _McKee Solid haste Sector
Eli.zabetii. Wenner Compliance FTydrogeologist Solid Waste Sector
Donnie Orr, Graharn;Caunty Sariifation Director
Crisp, Kim
From: Jonathan Pfohl Upfohl@mesco.com]
Sent: Thursday, May 17, 2012 2:53 PM
To: Crisp, Kim
Subject: Landfill Miscellaneous Information
Hi,
I simply want to keep you informed of some misc. info. that may be beneficial to you.
1.Let Mr. Orr know that I've sent a letter to Troy Harrison telling him the wells are repaired & the methane
report has also been sent to the SWS.
-y 2. We strongly recommend not starting to remove any trees from the landfill without consulting with us first.
We have previously been very successful in gaining relief from this requirement from the regulators.
3. We do recommend permanently marking the estimated waste boundary. Rebar/fence posts driven in the
ground either painted or white PVC pipe slid over is typical. There is waste in the top east field that I believe
Mr. Orr was unaware of I can provide a drawing upon request.
4. The water quality results will be submitted to the SWS once received from the lab but before the June 1, 2012
deadline.
If you have any questions call anytime,
Thanks,
Jonathan
Jonathan Pfohl
Municipal Engineering Services
PO Box 97
Garner NC 27
Phone: (919) 772-53
Fax: (919 772-1176 \
Mobile (919) 696-1383 \