2201_INSP_20201117

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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
SLAS
COUNTY: CLAY
MSWLF
PERMIT NO.: 2201-MSWLF-1982
Closed
X
HHW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: 11/17/2020
FACILITY NAME AND ADDRESS:
Clay County Landfill
1160 Hinton Center Rd
Hayesville, NC 28904
Date of Last Inspection: 02/21/2017
GPS COORDINATES (decimal degrees): Lat.: 35.029396'
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Kevin Shaheen, Solid Waste Director
Telephone: [phone]
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
PO Box 118
Hayesville, NC 28904
PARTICIPANTS:
Kevin Shaheen, Clay County
Lee Hill, NCDEQ-Solid Waste Section
STATUS OF PERMIT:
Facility stopped receiving waste on April 9, 1994
Closure Letter issued on December 21, 1995
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
N/A
OBSERVED VIOLATIONS:
Long.:-83.784352'
A. 15A NCAC 13B .0503(2)(a)(ii) states that a site shall meet the following design requirements: "The
concentration of explosive gases generated by the site shall not exceed the lower explosive limit for the gases at
the property boundary."
B. 15A NCAC 13B .0203(d), which states: By receiving solid waste at a permitted facility, the permittee(s) shall be
considered to have accepted the conditions of the permit and shall comply with conditions of the permit. The
facility received a closure letter from the Solid Waste Section [Section] on December 21, 1995 which stated post
closure conditions. The closure letter Post Closure Condition 1 states: "MANAGEMENT OF LANDFILL GAS:
The owners 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)."
Page 1 of 4

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
On November 16, 2020, facility staff emailed results from the 2019 and 2020 landfill gas monitoring events. Landfill gas
detections above the LEL were observed in two boundary wells: GP-1 and GP-4. Monitoring well GP-1 had exceedances
of the Lower Explosive Limit (LEL) on June 25, 2019 (436% of LEL), December 20, 2019 (314% of LEL), March 30,
2020 (134% of LEL), June 30, 2020 (102% of LEL), and September 28, 2020 (148% of LEL). Monitoring well GP-4 had
exceedances of the Lower Explosive Limit (LEL) on June 25, 2019 (666% of LEL), September 28, 2019 (124% of LEL),
December 20, 2019 (570% of LEL), March 30, 2020 (260% of LEL), June 30, 2020 (386% of LEL), and September 29,
2020 (612% of LEL).
Clay County is in violation of 15A NCAC 13B .0503(2)(a)(ii) and 15A NCAC 13B .0203(d) in that during the June
25, 2019, September 28, 2019, December 20, 2019, March 30, 2020, June 30, 2020, and September 29, 2020 landfill
gas monitoring events, landfill gas exceedances were detected in facility boundary wells.
To achieve compliance, Clay County must immediately take all necessary steps to ensure protection of human health due
to the exceedance of landfill gas noted at the site, including but not limited to the following:
1. Immediately increase the frequency of landfill gas monitoring for GP -I and GP-4 to monthly.
Monthly landfill gas monitoring will remain in effect until the Section approves a return to quarterly
routine gas monitoring. All other landfill gas wells may continue to be monitored on a quarterly basis as
required.
2. Within 30 days of the date of this inspection report, submit a landfill gas assessment plan of action
to Elizabeth Werner, Hydrogeologist, for review and approval. The plan shall contain the following
information at minimum:
a. Perform a subsurface investigation in the areas of GP-1 and GP-4 to ensure wells are not located
directly in or in close proximity to the closed waste mass. Include any corrective action needed,
such as the relocation of existing wells or installation of new wells.
b. Verify the location of the edge of waste and its proximity to GP-4 and the eastern property
boundary.
c. Investigate the potential migration of gas into the home located at 1315 Hinton Center Road
(parcel number 556000900058). The investigation shall include monitoring in and around the
structure, especially any crawl space or basement. If it is determined that gas has migrated to
this property, a detailed description of both short and long term corrective actions necessary to
mitigate risk to public health must be provided.
3. Contact Elizabeth Werner at 919-707-8253 or [e-mail] if you have questions
about the items listed above necessary to complete the landfill gas assessment. The plan may be
submitted electronically via email to:
Elizabeth Werner, Hydrogeologist
NCDEQ — Division of Waste Management
[e-mail]
919-707-8253
4. The results of the investigations above may require additional onsite corrective action to prevent
future exceedances and migration of landfill gas beyond the property.
It is highly recommended that the County install a combination explosive gas meter (Kiddie KN-COEG-3
Nighthawk Plug -In or similar) inside all onsite structures: scale house, tool/storage shed, and
recycle/collection facility for the protection of your employees and facility users. Likewise, the County
should consider the installation of a gas meter in the offsite home noted above.
Page 2 of 4

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
• ti
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SCALES ry
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Map from the Annual Water Quality Sampling Report
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.
ADDITIONAL COMMENTS
1. The closed landfill consists of three waste disposal areas. Two of the areas are located to the southwest of
Hinton Center Road and the other is located across Hinton Center Road.
2. The Landfill Gas Monitoring Plan was approved on August 22, 2017 and the Landfill Gas Monitoring Well
Installation Report was submitted to the section on April 26, 2018. Landfill gas monitoring records for 2019 and
2020 were supplied by email. Landfill gas exceedances at one or more boundary wells were observed during all
monitoring events. Please see Observed Violations section of this report for more information and
Page 3 of 4

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
required actions.
3. Please ensure all future exceedances of the LEL of landfill gases are reported to the Section as required.
4. Groundwater monitoring is conducted on an annual basis with the last sampling event occurring on December
19, 2019. The results from the sampling event were submitted to the section on March 31, 2020.
5. All waste disposal cells are secured by gates or chains.
6. Good vegetative cover was observed on all disposal areas and the cells were last mowed in October 2020.
7. All waste disposal areas had edge of waste markers (EOW) installed at the time of inspection.
8. The groundwater and landfill gas monitoring wells were observed to be locked and the paths to the wells were
being maintained. Landfill gas monitoring well GP-4 appears to be located approximately six feet from the
edge of waste marker and landfill gas monitoring well GP -1 is in close proximity to the delineated edge of
waste. A subsurface investigation needs to be performed to ensure the wells are not placed in or in close
proximity to the waste mass. See Observed Violations section of this report.
9. Positive drainage is being maintained and no ponding water was observed on the disposal cells.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Lee Hill
DN: cn=Lee Hill, o=Solid Waste
Section, ou=Field Operations
Branch, email=[e-mail],
c=US
Date: 2020.12.01 11:43:25-05'00'
Lee Hill
Environmental Senior Specialist
Regional Representative
Phone: [phone]
Sent on December 1, 2020 to
X
Email
Hand delivery
US Mail
Certified No. f2
Kevin Shaheen by
Copies: Deb Aja, Western District Supervisor — Solid Waste Section
Debbie Mauney, County Manager — Clay County
Page 4 of 4