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HomeMy WebLinkAbout3801_ROSCANS_2012IX 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 ?; cl \ ow ul , § 2 22f222§43 \\\\)2§ . )P,,V )§k§\\) | � °/$gc jE en _/ q jr m - /C\\\ '\ \\�\ '0 \ CD 0 \ (/ - � � rTi cow ALINED MONITORING �%f_* En,rmc►a SOLID WASTE LANDFILL n _�.�� a_ G�xmcun ��HC�iA . \\\ \ 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 \