5803_ROSCANS_1999

r .n
NORTH CAROLINA DEPARTMENT OF
w ENVIRONMENT AND NATURAL RESOURCES
. `
February 15, 1999 DIVISION OF WASTE MANAGEMENT
DENR CERTIFIED MAIL
` RETURN RECEIPT REQUESTED RECEIVED
Mr. Chris Wease N.C. Doi. ~Ji=NR
Madison County Manager
JAMEB B. HUNTJR. GourtL...use Box 579 FEB A $ Ig99-
GovERNOR Marshall, NC 28753
Winston--•SaIPMI
Re: NOTICE OF VIOLATION Regional Cf f icE,
Madison County, Permit #58-03
WAYNE MCDEVITT
SECRETARY Dear Mr. Wease:
You are hereby informed that the Madison County Landfill, Permit #58-03,
located on 101 Brigman Farm Road, Marshall, North Carolina, is in violation of the North
Carolina Solid Waste Management Rules codified at Title 15A Subchapter 13B of the
`WILUAM L. MEYER North Carolina Administrative Code (NCAC), specifically:
DIRECTOR
- 15A NCAC 13B .1628(e)(1)(F) requires all owners or operators of municipal
" � � ` �j solid waste landfill (MSWLF) units, using the Local Government Financial Test
to satisfy the financial assurance requirement, to submit annual updates of the
7fK. financial test letter to the Division within 120 after the close of each fiscal year.
Tina �•-._ A.• - CS. .,'_ ! 11... ....... yI...� A All 0 LAy, ..1 .-.t ..
iiv uili dial uFdGtG VVdJ VIIIVICIIIy uuC VII 1•dVVCI11UG1 1, 1UZV HJ VI Lhe UGIC VI
this letter, the Division of Waste Management has not received an updated financial test
letter from Madison County. 5ased on the foregoing, Nladison County is required `c
comply with 15A NCAC 13B .1628(b) by taking the following action:
1. Within 14 days of receipt of this notice, submit an updated financial
assurance test using estimates based on current dollars for Madison
County's fiscal year ending June 30, 1998;
2. Take any and all steps necessary to ensure that Madision County wiii meet
Nf. the liability requirements of the Local Government Commission using
- ti closure and post -closure cost estimates based on current dollars for the
fiscal vaar ending June 30, 1999
as :t; :•,_
Be advised that pursuant to the North Carolina General Statute 130A-22(a) and
15A NCAC 13B Section .0701-.0707, the Solid Waste Section is prepared to issue an
administrative penalty of up to $5,000.00 per day for failure to comply with the
requirements and schedule of this notice.
Thank you for your anticipated cooperation in this matter. If you have any
question, please call Ms. Kris Callahan at [phone] extension 270.
Since ly,
flip . Prete, Head
Field Operations Branch
cc: Julian Foscue, Western District Supervisor
401 OBERLIN ROAD, SUITE ISO, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 Oq POST -CONSUMER PAPER

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
April 9, 1999
Mr. Chris Wease
DIVISION OF WASTE MANAGEMENT
IuR
N.C. Dept. Q'I aQ i
rt GoVEarLOR Madison County Manager Arn
3 ` Courthouse, Box 579 Winston-Salem
Marshall, NC 28753 1 (�f f IC8
Regions
WAYNE MCDEVITT Re: Correction of Violation
SECRETARY Madison County, Permit #58-03
Dear Mr. Wease:
Rk
' This letter is to inform you that we have received Madison County's
WILLIDIRECTOR L. MEYER
DIRE-1; annual Local Government Financial Test letter. The requirements of the
O
February 15, 1999 Notice of Violation have been satisfied and the violations
corrected.
Thank you for your timely cooperation in this matter.
Sincerel --
P ' ip J. Prete, Head
Field Operations Branch
cc: Julian Foscue, Western District Supervisor
James Patterson, Waste Management Specialist
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL. OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% P,ECYCLED/10% POST -CONSUMER PAPER

}
Sandra Tolley MADISON COUNTY _. •
Chair
Commissioner's Offi J
Jerry Wallin
Vice- Chair
Reese Steen, DDS
Member
October 11, 1999
Post Office Box 579
Marshall, NC 28753
Telephone [phone]
Mr. James C. Coffey
NC DENR
Division of Waste Management - Solid Waste Section
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605
Subject: Madison County Landfill
Permit Number 58-03
Dear Mr. Coffey:
Chris Wease
County Manager
This letter is written in response to correspondence from the North Carolina Department of Environment
and Natural Resources (DENR) to the Madison County Solid Waste Director dated September 29, 1999.
The September 29, 1999 letter discussed four issues. By this letter, Madison County (County) is
responding to two of the four issues: the DENR inquiry regarding permit renewal and infrastructure design
and construction. The County understands that the two remaining issues will be addressed by a Permitting
Engineer and Mr. Jim Patterson, Area Waste Management Specialist. Mr. Jim Brown, the Madison
County Solid Waste Director, will be available to assist DENR as necessary.
Permit Renewal
Madison County requests that the North Carolina Department of Environment and Natural Resources
(DENR) renew Permit Number 58-03 for an additional five year operating period. The County does not
request chang:s to, the operaing conditions or waste streams received at the facility.
Evaluation of Landfill and Infrastructure Design and Construction
The September 29, 1999 letter states that "one of the monitoring wells has detected an increase above
background for one of the Appendix ! constituents, the owner/operator must determine the source of this
release. "
The Fletcher Group, Inc., an enviromnental engineering firm with offices in Asheville, North Carolina,
conducts semi-annual water quality monitoring on behalf of the County. A groundwater sample collected
during routine monitoring on April 21, 1999 contained 1.5 micrograms per liter (µg/L) of 1,1,1-
Trichloroethane. This compound was detected in one well, MW-7. No other organic compounds were

Mr. James C. Coffey
October 8, 1999
Page 2 of 3
detected at MW-7 or any of the additional monitoring wells and surface sampling locations. The NCAC
Title 15A Subchapter 2L groundwater standard for 1, 1, 1 -Trichloroethane is 200 µg/L.
The source of the 1, 1, 1 -Trichloroethane appears to be historic farm maintenance operations that occurred
in the area where MW-7 was installed. Tfiis conclusion regard ingest the source area is based on owe ge c
farm operations and the construction of monitoring well MW-7. A figure showing the maintenance area
and MW-7 is attached.
The permitted facility was developed in 1991 and 1992 on land that was formerly the Brigman farm. As
shown on a drawing titled "Proposed Sanitary Landfill - Site Plan" prepared by Law Engineering and
submitted to DENR for review on July 15, 1991, three farm buildings (a barn and two equipment and
materials storage buildings) were located where MW-7 was installed. One of the two equipment and
materials storage buildings was located approximately forty feet upgradient of MW-7. The second was
situated in approximately the same location as MW-7.
During construction of the sanitary landfill, the three farm buildings were demolished and removed.
Approximately 15 to 20 feet of fill were placed in this area during construction. Monitoring well MW-7
was installed in this location in 1995, after the fill was placed.
The total depth of monitoring well MW-7 is 33 feet. Based on interpretations of well construction
information by The Fletcher Group, MW-7 appears to be screened from 23 to 33 feet below ground
surface. In summary, the ground surface when the farm equipment and related maintenance area was in
use, was some three to eight feet from the zone presently screened by MW-7.
Reference literature states that the compound 1, 1, 1 -Trichloroethane is used as a solvent, aerosol
propellant, pesticide, and metal degreaser. Historically, all of these uses were common in the area
surrounding MW-7.
In evaluating the potential source of the 1, 1, 1 -Trichloroethane, the County has also considered the active
Municipal Solid Waste landfill cell. The direction of regional groundwater flow is generally from east to
west. As such, water quality issues at MW-7 would be expected to be evident at an earlier date in the two
monitoring wells (MW-3 and MW-4) that are downgradient of the landfill and upgradient of MW-7.
The issue related to 1,1,1-Trichloroethane in MW-7 has not appeared in MW-3 or MW-4. Historic?Ji_y,
volatile organic compounds (VOCs) have not been detected in samples collected from monitoring well
MW-4. Three VOCs, methylene chloride, acetone, and dichloromethane, have been detected in samples
collected from MW-3. Only methylene chloride has been detected more than one time. The most recent
VOC detections in MW-3 were in April of 1997 and 1998. The Fletcher Group, in a letter to Mr. Larry
Rose dated July 27, 1997, presented an evaluation of the VOC detections. Their findings indicated that
the VOCs were introduced into MW-3 in October 1996, when a Solid Waste Department employee
sprayed a monitoring well lock with WD-40. As a further check, James E. Clemmer, Ph.D., P.E., a
chemical engineer on The Fletcher Group staff, evaluated the array of VOCs detected in MW-3 and MW-
7, and stated that 1, 1, 1 -Trichloroethane is not related to the VOCs detected at MW-3.
Leachate quality is monitored semi-annually as part of the Detection Monitoring program. A review of
leachate analytical data shows that in the two years prior to April 1999, methyl ethyl ketone was the only

i
K
Mr. James C. Coffey
October 8, 1999
Page 3 of 3
detected VOC. None of the data suggests a connection between leachate quality and groundwater quality
at MW-7.
Conclusion
Madison County has evaluated two potential sources for the 1,1,1-Trichloroethane: the former farm
maintenance operations and landfill leachate. Considering the proximity of the MW-7 well screen to the
former farm maintenance area, and the absence of analytical data connecting leachate and groundwater
quality, the low concentration of 1, 1, 1 -Trichloroethane appears to have come from the historic farm
maintenance operations.
The next round of semi-annual water quality sampling is scheduled this month. Madison County will
continue working with Mr. Mark Poindexter, of DENR, to monitor groundwater quality near MW-7.
Finally, the September 29, 1999 letter discussed two additional matters: Effectiveness of the Operations
Plan and Past Compliance History. The Madison County Solid Waste Department looks forward to
assisting the Permitting Engineer in conducting the associated reviews. Please contact Mr. Jim Brown at
[phone], if you would like to arrange a time for the reviews.
If I may be of any assistance, please feel free to contact me directly. Thank you for your assistance with
this important matter.
Sincerely,
Madison County,
Chris Wese
County Manager
attachments
cc: Board of Commissioners
Jim Brown/Madison County Solid Waste Department

V
- - , vet I \ \ `, \ ` \ 8�p \ j /� I W - _- 1500 -- - '• / b l--1(t7 0
\ I` \\cam\1� 1 `�//i\ I --- -/' - ❑ LE�n� I
is
Lo
y _
r
-'SEDWENT -WIN
.;� y C NSiRU�CTIDN DEBRIS LANDFILL � , •, `\ � \ ` \ I ' yr \ ,� � � �•
f
\ \ rE dPkfi1YENTFt?R 1 F� �`'\\f \ ti r• — CELL NO. ...I ` — \ \� \\. \. '.G.
\ cca�ttt * Ai�TERIA—
i �STOkACE B�11E QINGS Mali
�• EOFFtiER r1�' (!`. " '', ;_ �; \ W `,\ _20oo '/ I ` .` '�'' i _ ID
FARM A(J41 JT�IAiNCE u4RG ^
�f.. A_ 4 _'•. / 7! ; I , 2 \ f f' 1 , ; ACCESS *RbAD I 1
[.`HATE `'•!• w �• �I •f Mi�r-Bt�\ ;
r� 1_UYNV rurar I' mY1t a • 1 - _ '
]4n
/jJff 1
SE
II ••1f/ENT `
� 1k Q BASIPt�
as iCOUNTY= °
OPER TWO LANDFL� •' k f �f j j i . I - •p
i
GRAPHIC SCALE
'
LEGMii
RING WELL LOGATI�ON '� / Sao a Z50 sao ,�, a
A SW-2 SURFM"MONIIACE WATER IAPLE LOCATION
(IN rEE%)
THE ALE - CC__p �±a �E' 1
I •,
cHE.=� GROUP FAR FAIRM AREA
i — - — — — - Er>Igirl wing al tions L�CATIOt+t MAP o
�.
`jL- MAIDMM C70 *ff Y OPERATM L ANDFLL--
'� kSHE1 LL . MOR'Th CAROIJHA IfAADF.7VN L•LJ7.It•1 ■ i NORTH CsAROMA