The URL can be used to link to this page

Home My WebLink About5802_ROSCANS_2010@McGM A S S O C I A T E S March 31, 2010 RECEIVr ® SOLID WASTE SECTION �ASHEVILLE REGIONAL OFFICE Cnr Mr. Zinith Barbee Hydrogeologist Solid Waste Section Division of Waste Management North Carolina Department of Environment and Natural Resources 1646 Mail Service Center Raleigh, North Carolina 27699-1646 RE: Madison County Closed MSW Landfill Permit No. 58-02 Madison County, North Carolina Dear Mr. Barbee: On behalf of Madison County, North Carolina, McGill Associates is pleased to submit for your review and approval, the enclosed Landfill Gas Monitoring Plan for the Madison County Closed MSW Landfill, Permit No. 58-02. A Facility Plan for the site is included as Figure 1, Facility Plan, Madison County Closed MSW Landfill, Permit No. 58-02, Madison County, Madison County, North Carolina. The County intends to install the proposed landfill gas monitoring probes, at the locations shown on the Facility Plan, in a timely manner once approval of the Landfill Gas Monitoring Plan is received. Please find enclosed a hard copy and a digital copy of the Landfill Gas Monitoring Plan for the Madison County Closed MSW Landfill, Permit No. 58-02. E n g i n e e r i n g P l a n n i n g a F i n a n c e Alc Gill Associates, P.A. • P.O. Box 1159, Asheville, NC 18802 55 Broad Sn eel, Asheville, AIC 18801 818-151-0575 • Fax: 818-151-1518 Mr. Zniith Barbee March 31, 2010 Page 2 Thanks in advance for your attention to the County's request. Please do not hesitate to contact us should you have any questions regarding this submittal. Sincerely, McGILL ASSOCIATES, P.A. Project Enclosures H. STFERRY, PE cc: "Andrea Keller, NCDENR Solid Waste Section, w/enc Jim Huff, Director, Madison County Solid Waste Department, w/o enc 09.00729/letters/10 0331 — Z Barbee -Madison Cty Closed LF 58-02.doe ii REC'7!**1./ D � Fb. [� 2 APO - 1 2010 SOLID WASTE SECTION ASHEVILLE REGIONAL OFFICE LANDFILL GAS MONITORING PLAN MADISON COUNTY CLOSED MSW LANDFILL PERMIT NO.58-02 MADISON COUNTY, NORTH CAROLINA WILLIAM H. SPERRY, PE gMcGillA Engineering • Planning • Finance Asheville, North Carolina March 2010 00.00729 0 Landfill Gas Monitoring Plan Madison County Closed MSW Landfill Permit No. 58-02 Table of Contents INTRODUCTION LANDFILL GAS CONTROL a) Methane Gas Concentration Limits b) Routine Landfill Gas Monitoring Program c) Methane Gas Response Plan APPENDICES: Appendix 1: Landfill Gas Control Plan for Madison County Closed MSW Landfill Appendix 2: Landfill Gas Monitoring Probe FIGURES: Figure 1: Facility Plan, Madison County Closed Landfill, Permit No. 58-02, Madison County, Madison County, North Carolina i INTRODUCTION Madison County, North Carolina presently maintains the Madison County Closed Municipal Solid Waste Landfill, Permit No. 58-02, at 389 Long Branch Road (SR. 1582), Marshall, North Carolina 28753. The facility was officially closed per a letter to the North Carolina Department of Enviromnent and Natural Resources (NCDENR) dated December 21, 1995. The facility encompasses approximately 32.95 acres within the proposed Facility Boundary as shown in Figure 1, Facility Boundary, Madison County Closed MSW Landfill, Permit No. 58-02. Within the Facility Boundary, three separate disposal areas totaling approximately 9.35 acres (1.97 acres, 5.23 acres, and 2.15 acres respectively) were identified as being utilized for the disposal of municipal solid waste. The approximate boundaries of these areas are shown on the aforementioned Figure 1. The Facility Boundary is bounded on the north by property owned by Madison County and on the south by Long Branch Road (S.R. 1582). On the northeast, the Facility is bounded by property owned by Oakley (Wanda Edwards) Wyatt and on the southeast by property owned by Madison County and presently used for the Madison County Animal Shelter and the Madison County Transportation Department. On the west, the Facility is bounded by property owned by Joel L. and Diane P. Edwards and property owned by J. V. and Wanda Edwards. The groundwater monitoring network consists of an upgradient or background monitoring point (BG-Spring-Old) located to the north of the Facility and two (2) down gradient monitoring wells (MW-01-Old and MW-02-Old). Monitoring point MW-01- Old is located in the south central portion of the Facility and monitoring point MW-02- Old is located in the southeast comer of the Facility. Two (2) surface water monitoring points are also included as a part of the groundwater monitoring system. Surface water monitoring point SW -I -Old is located to the east of the Facility and surface water monitoring point SW-2-Old is located to the southwest of the Facility. Landfill gas monitoring has not been conducted at the site on a routine basis. However, the County is proposing to install approximately eleven (11) strategically located landfill gas monitoring probes around the perimeter of the Facility Boundary as shown on Figure 1, Facility Plan, Madison County Closed MSW Landfill, Permit No. 58-02. A detail of the proposed landfill gas monitoring probes is shown in Appendix 2. Once installed, these probes will be monitored on a quarterly basis by the County. March 2010 1 Project it 09.00729 LANDFILL GAS CONTROL a. Methane Gas Concentration Limits Madison County must ensure that: i. The concentration of methane gas generated by the landfill does not exceed 25 percent of the Lower Explosive Limit* (25% LEL) for methane in landfill structures (excluding gas control or recovery system components); and ii. The concentration of methane gas does not exceed 100 percent of the Lower Explosive Limit (100% LEL) for methane at the landfill property boundary. b. Routine Landfill Gas Monitoring Program Madison County will implement a routine landfill gas monitoring program to ensure that the standards of (a) are met. See Appendix 1 for the Landfill Gas Control Plan for the Madison County Closed MSW Landfill, Permit No. 58-02, located at 389 Long Branch Road (S.R. 1582), Marshall, North Carolina 28753. i. The type and frequency of monitoring must be determined based on the following factors: I. Soil conditions; II. The hydrogeologic conditions surrounding the facility; III. The hydraulic conditions surrounding the facility; IV. The location of facility structures and property boundaries. ii. The minimum frequency of monitoring will be quarterly. c. Methane Gas Response Plan If methane gas levels exceeding the limits specified in (a) are detected, the owner or operator will: Irmnediately take all necessary steps to ensure protection of human health, i.e. no smoking, temporarily abandon the structure and notify the Division of Solid Waste Management. March 2010 2 Project # 09.00729 LANDFILL GAS MEASUREMENTS - FIELD WORKSHEE'r -Madison County Closed MSW Landfill: Permit #58-02 Name of Person Taking Readings: _{r4 AW,1- At F?-Date: 3/ a 9// Weather Conditions: C�FA,p, . S% �H (Q,�y Ambient Temperature: Atmospheric Pressure: 36. / /f4�- w txj Gas Monitoring Equipment: Gascope, Combustion Gas Indicator, Model 62S Mine Safety Appliances Company Factory Calibration Date: 3 a // Field Calibration Date: -6/02 %/,j C:\Documents and Settings\OwnerNy DocumentsVini s Documents\Landfill\Landfill Gas\58-02\LPG field Worksheet 58-02.doc 9 0 ii. Within seven days of detection, place in the operating record the methane gas levels detected and a description of the steps taken to protect human health; and iii. Within 60 days of detection, prepare and implement a remediation plan for the methane gas releases, place a copy of the plan in the operating record, and notify the Division of Solid Waste Management that the plan has been implemented. The plan will describe the nature and extent of the problem and the proposed remedy. - "Lower Explosive Limit" (LEL) means the lowest percent by volume of a mixture of explosive gases in air that will propagate a flame at 25' C and atmospheric pressure. March 2010 3 Project # 09.00729 APPENDICES APPENDIX 1 Landfill Gas Control Plan for Madison County Closed MSW Landfill Permit No. 58-02 LANDFILL GAS CONTROL PLAN FOR MADISON COUNTY CLOSED MSW LANDFILL PERMIT NO. 58-02 Each quarter, Madison County will monitor for landfill gas at the adjacent landfill structures and at or near the Facility Boundary by means of permanently installed landfill gas monitoring probes. The permanent probes will consist of a plastic stand pipe similar to a piezormeter used for groundwater detection. A typical permanent landfill gas monitoring probe is detailed in Appendix 2. The permanent probe will be constructed at a depth of approximately six (6) feet. The 6" diameter hole will contain a one (1) inch Schedule 40 PVC pipe. The bottom one foot (1') of the one (1) inch schedule 40 PVC pipe will be perforated. The bottom two (2) feet of the hole will be backfilled with non - carbonate pea gravel with a bentonite seal one (1) foot thick above it. The remaining three (3) feet will be backfilled with in situ soils. The one (1) inch PVC pipe will be extended approximately three (3) feet above the existing grade. The PVC pipe will be capped with a one (1) inch PVC cap with a one quarter (1/4) inch NPT hose barb which will be plugged or capped to prevent contamination. A minimum four (4) inch diameter schedule 40 PVC sleeve will be placed over the one (1) inch pipe and filled with clean masonry sand to within four (4) inches of the one (1) inch schedule 40 PVC cap. The top of the four (4) inch schedule 40 PVC pipe sleeve will be secured with a removable water tight cap. A marker post will be placed in close proximity to the probe. A permanent probe I.D. will be placed/painted on the marker post or the 4" schedule 40 PVC sleeve. The proposed permanent landfill gas monitoring probes have been strategically located around the perimeter of the Facility Boundary as shown on Figure 1, Facility Plan for the Madison County Closed MSW Landfill, Permit No. 58-02. The locations were chosen based on the relationship of solid waste disposal areas to property lines and adjacent landfill structures. The spacing of the monitoring probes is between 300 and 600 feet depending on location to the closed waste mass. Madison County's Closed MSW Landfill was not constructed with an impermeable base liner system and cap system. There may be a chance for landfill gas migration through the permeable in situ soils. The migration of landfill gas is induced by pressure gradients. The landfill gas will move from areas of high pressure to those of low pressure following the path of least resistance. The landfill gas generally migrates vertically until it reaches the landfill cap, where it may begin to flow horizontally. This occurs until it finds a pathway out through the permeable in situ soils. As the landfill gas migrates it will fill the void created by the monitoring point's gravel backfill whereupon a landfill gas detection device will detect and read the level of gas concentration. The six foot depth of the monitoring probes is to ensure a stable monitoring point. The only time a shallow monitoring point has not worked is in a very heavy, impermeable clay layer that acts as a seal to the migration of the landfill gas. If a clay layer is encountered during the construction of the monitoring points, it will either be moved beyond the clay or excavated to a depth that is in a conductive zone below the clay. March 2010 Appendix 1 - 1 Project # 09.00729 The level of methane gas (CH4), a constituent within the landfill gas, can be detected by use of an instrument designed to detect explosive gas concentrations. In this case, the instrument that will be used will be a landfill gas detection metering device specifically designed for use in monitoring landfill gas concentrations. The meter will be equipped with an internal vacuum pump capable of drawing gas from within the voids in the monitoring probe. Meter readings will depict methane gas (CH4) concentrations in percent of the Lower Explosive Limit (% LEL) and/or total percent methane gas concentration (% CH4) as well as the percent concentration of oxygen (% 02). Quarterly, a County employee or a contractor for the County will visit each monitoring point. The monitoring points will consist of all landfill gas monitoring probes and selected adjacent buildings or enclosures. Using a landfill gas detection metering device, the County will determine if landfill gas has filled the probes' voids. If the probe is near the facility boundary and the level of methane gas is detected at or above the lower explosive limit (100% LEL), it must then be determined if the gas is migrating across the facility boundary. If the probe is on the facility boundary or methane gas has migrated beyond the facility boundary, a remediation plan must be prepared and implemented by Madison County. Other points of monitoring will be the selected structures adjacent to and in close proximity to the landfill's Facility Boundary. Each structure will be monitored, for methane gas using the following methods: 1. All crawl spaces will be monitored (if applicable); 2. All corners in the structure will be monitored; 3. Any holes, cracks and pipes through the foundation will be monitored If methane gas is detected beyond 25% of the lower explosive limit (25% LEL) in any structure, check the calibration of the monitor and resample. If the reading is still above 25% of the LEL, evacuate the building and try to find the source of gas. If the source is found, try to remove and/or repair the source. If this fails, a remediation plan must be prepared and implemented by Madison County. March 2010 Appendix 1 - 2 Project # 09.00729 APPENDIX 2 Landfill Gas Monitoring Probe MARKER POST 4' MIN. 3' d 1' 4" SCHEDULE 40 PVC CAP, REMOVABLE 1" SCHEDULE 40 PVC CAP W/ �1/4" NPT HOSE BARB W/CAP 1" SCHEDULE 40 PVC 4" SCHEDULE 40 PVC LFILL V01D WITH P SCHEDULE 40PVC CRY SAND OHIA a EXISTING GROUND 3' BENTONITE PLUG NON -CARBONATE PEA GRAVEL 1' IXI-I-PERFORATONS TO BE 1/4" DIA. HOLES 0 1" O.C. O 1/4 POINTS 6" 1" SCHEDULE 40 PVC CAP 2' 1' NOTES: 6" 1. PROBE DEPTH MAY BE REVISED IN FIELD IF GROUNDWATER OR BEDROCK IS ENCOUNTERED. 2. PERMANENT PROBE I.D. TO BE PLACED/PAINTED 6' ON MARKER POST OR 4" SCHEDULE 40 PVC SLEEVE. LANDFILL GAS MONITORING PROBE NOT TO SCALE FIGURES FIGURE 1 Facility Plan Madison County Closed MSW Landfill Permit No. 58-02 Madison County Madison County, North Carolina gMcGM A S S O C I A T E S April 20, 2010 Mr. Zinith Barbee Hydrogeologist Solid Waste Section Division of Waste Management gcanrledb 1 °i3I'ro 0430 North Carolina Department of Environment and Natural Resources 1646 Mail Service Center Raleigh, North Carolina 27699-1646 Dear Mr. Barbee: 232010 RE: Madison County Closed MSW Landfill Permit No. 58-02 Madison County, North Carolina On behalf of Madison County, North Carolina, McGill Associates is pleased to submit for your review and approval, the enclosed revised Landfill Gas Monitoring Plan for the Madison County Closed MSW Landfill, Permit No. 58-02. The Landfill Gas Monitoring Plan has been revised to include, as Appendix 3, a Landfill Gas Measurements — Field Worksheet with the landfill gas probes noted as well as the selected structures that will be monitored. A revised Facility Plan for the site is included as Figure 1, Facility Plan, Madison County Closed MSW Landfill, Permit No. 58-02, Madison County, Madison County, North Carolina that notes the designated landfill gas probe numbers. The County intends to install the proposed landfill gas monitoring probes, at the general locations shown on the Facility Plan, in a timely manner once approval of the Landfill Gas Monitoring Plan is received. Please find enclosed a hard copy and a digital copy of the revised Landfill Gas Monitoring Plan for the Madison County Closed MSW Landfill, Permit No. 58-02. E n g i n e e r i n g a P l a n n i n g o F i n a n c e Me Gill A.ssoeimes, P.A. • P.O. Box 2259. Asheville, NC 28802 • 55 Brand Street, Ashow le, NC 28801 828-252-0575 • Faw 828-252-2518 LANDFILL GAS MONITORING PLAN MADISON COUNTY CLOSED MSW LANDFILL PERMIT NO.58-02 MADISON COUNTY, NORTH CAROLINA WILLIAM H. SPERRY, PE nMcGill A S S O C I A T E S Engineering • Planning • Finance Asheville, North Carolina March 2010 Revised April 2010 00.00729 INTRODUCTION Madison County, North Carolina presently maintains the Madison County Closed Municipal Solid Waste Landfill, Permit No. 58-02, at 389 Long Branch Road (S.R. 1582), Marshall, North Carolina 28753. The facility was officially closed per a letter to the North Carolina Department of Environment and Natural Resources (NCDENR) dated December 21, 1995. The facility encompasses approximately 32.95 acres within the proposed Facility Boundary as shown in Figure 1, Facility Boundary, Madison County Closed MSW Landfill, Permit No. 58-02. Within the Facility Boundary, three separate disposal areas totaling approximately 9.35 acres (1.97 acres, 5.23 acres, and 2.15 acres respectively) were identified as being utilized for the disposal of municipal solid waste. The approximate boundaries of these areas are shown on the aforementioned Figure 1. The Facility Boundary is bounded on the north by property owned by Madison County and on the south by Long Branch Road (S.R. 1582). On the northeast, the Facility is bounded by property owned by Oakley (Wanda Edwards) Wyatt and on the southeast by property owned by Madison County and presently used for the Madison County Animal Shelter and the Madison County Transportation Department. On the west, the Facility is bounded by property owned by Joel L. and Diane P. Edwards and property owned by J. V. and Wanda Edwards. The groundwater monitoring network consists of an upgradient or background monitoring point (BG-Spring-Old) located to the north of the Facility and two (2) down gradient monitoring wells (MW-01-Old and MW-02-Old). Monitoring point MW-01- Old is located in the south central portion of the Facility and monitoring point MW-02- Old is located in the southeast corner of the Facility. Two (2) surface water monitoring points are also included as a part of the groundwater monitoring system. Surface water monitoring point SW-1-Old is located to the east of the Facility and surface water monitoring point SW-2-Old is located to the southwest of the Facility. Landfill gas monitoring has not been conducted at the site on a routine basis. However, the County is proposing to install approximately eleven (11) strategically located landfill gas monitoring probes around the perimeter of the Facility Boundary as shown on Figure 1, Facility Plan, Madison County Closed MSW Landfill, Permit No. 58-02. A detail of the proposed landfill gas monitoring probes is shown in Appendix 2. Once installed, these probes will be monitored on a quarterly basis by the County. March 2010 1 Project # 09.00729 Within seven days of detection, place in the operating record the methane gas levels detected and a description of the steps taken to protect human health; and iii. Within 60 days of detection, prepare and implement a remediation plan for the methane gas releases, place a copy of the plan in the operating record, and notify the Division of Solid Waste Management that the plan has been implemented. The plan will describe the nature and extent of the problem and the proposed remedy. - "Lower Explosive Limit" (LEL) means the lowest percent by volume of a mixture of explosive gases in air that will propagate a flame at 251 C and atmospheric pressure. March 2010 3 Project # 09.00729 APPENDIX Landfill Gas Control Plan for Madison County Closed MSW Landfill Permit No. 58-02 The level of methane gas (CH4), a constituent within the landfill gas, can be detected by use of an instrument designed to detect explosive gas concentrations. In this case, the instrument that will be used will be a landfill gas detection metering device specifically designed for use in monitoring landfill gas concentrations. The meter will be equipped with an internal vacuum pump capable of drawing gas from within the voids in the monitoring probe. Meter readings will depict methane gas (CH4) concentrations in percent of the Lower Explosive Limit (% LEL) and/or total percent methane gas concentration (% CH4). Depending on the particular meter utilized, other readings such as the percent concentration of carbon dioxide (% CO2) and percent concentration of oxygen (% 02) will be recorded along with probe pressure or vacuum. Quarterly, a County employee or a contractor for the County will visit each monitoring point. The monitoring points will consist of all landfill gas monitoring probes. At the beginning of each monitoring cycle, the County will complete the top half of the Landfill Gas Measurements — Field Worksheet form included in Appendix 3. Using a landfill gas detection metering device, the County will monitor each probe to determine if landfill gas has filled the probes' voids. The readings and the time of the reading at each probe will be recorded on the Landfill Gas Measurements — Field Worksheet form. If the probe is near the facility boundary and the level of methane gas is detected at or above the lower explosive limit (100% LEL), it must then be determined if the gas is migrating across the facility boundary. If the probe is on the facility boundary or methane gas has migrated beyond the facility boundary, a remediation plan must be prepared and implemented by Madison County. Other points of monitoring will be the selected structures adjacent to and in close proximity to the landfill's Facility Boundary. The time and the meter readings for each structure will be recorded on the Landfill Gas Measurements — Field Worksheet form. Each structure will be monitored, for methane gas using the following methods: 1. All crawl spaces will be monitored (if applicable); 2. All corners in the structure will be monitored; 3. Any holes, cracks and pipes through the foundation will be monitored If methane gas is detected beyond 25% of the lower explosive limit (25% LEL) in any structure, check the calibration of the monitor and resample. If the reading is still above 25% of the LEL, evacuate the building and try to find the source of gas. If the source is found, try to remove and/or repair the source. If this fails, a reinediation plan must be prepared and implemented by Madison County. March 2010 Appendix 1 - 2 Project It 09.00729 Revised: April 2010 MARKER POST 4' MIN, S a J r- I NOTES: 4" SCHEDULE 4D PVC CAP, REMOVABLE 1" SCHEDULE 40 PVC CAP W/ 1/4" NPT HOSE BARB W/CAP 1" SCHEDULE 40 PVC 4" SCHEDULE 40 PVC FILL VOID WITH MASONARY SAND TO WITHIN 4" OF 1" SCHEDULE 40 PVC CAP EXISTING GROUND SOIL BACKFILL BENTONITE PLUG NON -CARBONATE PEA GRAVEL PERFORATONS TO BE 1/4" DIA, HOLES 0 1" O.C. 0 1/4 POINTS 1" SCHEDULE 40 PVC CAP 1. PROBE DEPTH MAY BE REVISED IN FIELD IF GROUNDWATER OR BEDROCK IS ENCOUNTERED. 2. PERMANENT PROBE I.D. TO BE PLACED/PAINTED ON MARKER POST OR 4" SCHEDULE 40 PVC 6 SLEEVE, NOT TO SCALE LANDFILL GAS MEASUREMENTS — FIELD WORKSHEET Madison County Closed MSW Landfill: Permit #58-02 Name of Person Taking Readings: Weather Conditions: Atmospheric Pressure: Gas Monitoring Equipment: Field Calibration Date: Date: Ambient Temperature: Gas Readings Field Worksheet Probe- 1. Probe GP-1 GP-2 GP-3 GP-4 GP-5 GP-6 GP-7 GP-8 GP-9 OP-10 GP-1 I Animal —Shelter Trans. Building P:\2009\09.00729\Misc\100420 -REV -App 3 - LrO Field Worksheet -Madison Cty.cloc FIGURE 1 Facility Plan Madison County Closed MSW Landfill Permit No. 58-02 Madison County Madison County, North Carolina 4*i MUM North Carolina Department of Environment and Beverly Eaves Perdue Governor CERTIFIED MAIL RETURN RECEIPT REQUESTED 7009 1680 0000 7514 8246 Clearwater Well Drilling 547 Upper Shut-in Road Hot Springs, North Carolina 28743 Attn.: Mr. Rex Meadows NC Certification No. 2113 Division of Water Quality Coleen H. Sullins Director November 2, 2010 Reference: NOTICE OF VIOLATIONS of the NORTH CAROLINA WELL CONSTRUCTION STANDARDS NOV-2010-2C-0018 BIMS Incident 200902510 Well Located on PIN 9716-66-9635 Madison County, N.C. Dear Mr. Meadows: Natural Resources Dee Freeman Secretary The Aquifer Protection Section of the Division of Water Quality (DWQ) is responsible for the regulation of well construction activities within the State of North Carolina. On October 12, 2009, the Asheville Regional Office (ARO) of DWQ inspected a water supply well located on the property of Joel and Diane Edwards, 79 Long Branch Road, Marshall, N.C. The field inspection verified data submitted to the Solid Waste Section indicating that the subject well was located within 500 ft of a closed, municipal landfill owned by Madison County. The well identification tag indicated that the well was drilled November 30, 2006. The landfill waste cell closest to the subject well stopped receiving waste and was subsequently closed as of December 21, 1995. Although the identification plate on the well indicates a driller registration number of 922, you stated in a conversation with me on October 16, 2009 that in fact, you drilled the subject well. You are also the registered agent for Clearwater Well Drilling, Inc. and Clear Water Well & Pump Corporation. Therefore the following violation exists: VIOLATION: The well was installed at distance less than 500 feet from the landfill boundary, as required by Rule 15A NCAC 2C.0107(a)(2)0). Based on a site survey, the well is located approximately 300 ft from the nearest waste cell boundary. Because this well is contaminated, you are not required to chlorinate the well prior to abandonment. REQUIRED CORRECTIVE ACTION for Violation: Please abandon the well as required by 15A NCAC 2C.0113(b) and submit a well abandonment record (GW- 30). North Carolina Division of Water Quality— Asheville Regional Ofce 2090 U.S. Highway 70, Swannanoa, N.C. 28778 Phone (828) 296-4500 FAX (828) 299-7043 Customer Service 1-877-623-6748 Internet: h2o.enr.state.nc.us Nofle rthCarolina Naturally An Equal Opportunity 1 Afirmallve Action Employer