1202_INSP_20170308

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: BURKE
Closed MSWLF X HHW White goods Incin T&P FIRM PERMIT NO.: 12-02
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: March 2 & 8, 2017 Date of Last Inspection: May 23 & 27, 2011

FACILITY NAME AND ADDRESS:
East Burke (Rhodhiss) MSW Landfill Rhodhiss Road (SR-1611)
Rhodhiss, NC 28667 GPS COORDINATES: N: 35.762924° W: -81.446144°
FACILITY CONTACT NAME AND PHONE NUMBER:
Chris Hollifield – General Services Director/County Engineer
828-764-9062
[e-mail]
FACILITY CONTACT ADDRESS:
Bryan Steen – Burke County Manager
P.O. Box 219
Morganton, NC 28680 828-764-9350
[e-mail]

PARTICIPANTS: Kris Riddle, Environmental Senior Specialist, Solid Waste Section (Section)

STATUS OF PERMIT: Permit No. 1202. Site Closed in accordance with the requirements in 15A NCAC 13B .0510.
PURPOSE OF SITE VISIT:
Comprehensive site inspection. STATUS OF PAST NOTED VIOLATIONS:
None.
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .0503(2)(a) CORRECTIVE ACTIONS ONGOING. At the time of this inspection, Landfill
Gas Monitoring reports submitted to the Section by the facility demonstrate that the closed site has not met the design standards for landfill gas in 15A NCAC 13B .0503(2)(a) which 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
(ii) The lower explosive limit for the gases at the property boundary.”

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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The Closure Letter for Burke County Landfill, Permit No. 12-02, dated July 9, 1992, states, “All disposal sites
either operating or closed, are subject to the explosive gas requirements of Section .0503(2)(a)”.
Since the last inspection of the facility by the Section, compliance work has been conducted at the site to address
landfill gas (LFG) concerns. The LFG Monitoring Report for First Quarter 2017 (Permit #12-02) was submitted to the Section on February 13, 2017. The report revealed methane exceedances above the lower explosive limit (LEL)
for methane at the facility boundary in LFG monitoring wells GP-1, GP-3, and GP-4. These results are consistent with previous results. As per the Landfill Gas Remediation Plan approved by the Section in 2015, three passive landfill gas vents were installed at the facility in May 2016. As per the approved Landfill Gas Remediation Plan,
after one year of routine landfill gas monitoring following the installation of the vents, the County will make an assessment regarding the effectiveness of the plan.

To achieve compliance Burke County must continue to work with Jaclynne Drummond, Compliance Hydrogeologist, to address landfill gas exceedances and implement measures in a plan approved by Ms. Drummond on September 18, 2015. If the plan does not reduce the methane in the wells then additional
corrective measures will be required and additional compliance actions may be taken.

2. 15A NCAC 13B .0510(c) CORRECTIVE ACTIONS ONGOING. 15A NCAC 13B .0510(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 Closure Letter for Burke County Landfill, Permit No. 12-02, dated July 9, 1992, states, “Post-closure necessary
maintenance for this facility shall consist of whatever measures, procedures, and activities are required to maintain this facility in compliance with those closure conditions specified within this letter.”
The closure conditions specified in the Closure Letter, dated July 9, 1992, include the following operational requirements:
(a) “Final cover, two (2) feet of suitable compacted earth;
(b) Permanent erosion control measures, as necessary to prevent silt from moving off-site and excessive on-site
erosion; (c) Drainage control measures, as necessary to prevent the impoundment of surface water over waste; (d) Vegetation requirements, stabilization with native grasses; and
(e) Leachate control, containment on-site or properly discharged off-site.”

Since the last inspection of the facility by the Section, compliance work has been conducted at the site to address maintenance concerns including: tree removal from various areas of the landfill cap to allow for the installation of
landfill gas monitoring wells and passive vents and edge of waste markers have been installed around the entire disposal area at the site. The placement of the edge of waste markers at the site revealed that the landfill is covered with mature trees and woody vegetation to the point where it cannot be determined if the specified closure
conditions listed above are being met. The integrity of the cap of the landfill must be properly maintained.
To achieve compliance, within ninety (90) days from the receipt of this inspection report, Burke County must develop and submit to the Section a written maintenance plan which ensures landfill cap integrity. At a minimum this plan should include a schedule for routine inspections of the
following: a. Vegetation on the cap is mowed sufficiently to allow for inspection of the cap; b. Management of trees and woody vegetation (including dead, dying, or diseased trees)
and maintenance of the cap of the landfill, such that the landfill can readily be inspected; c. Any surface erosion is repaired and re-seeded as necessary;
d. Erosion is controlled and repaired to ensure that no silt or sediment leaves the site;
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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e. Any leachate seeps in the cap are repaired;
f. Any areas of bare soil are reseeded to establish a vegetative cover; g. Any areas of subsidence of the cap are repaired, re-sloped and reseeded as necessary to ensure the controlled shedding of surface water from the cap;
h. The edge-of-waste markers are maintained in good repair; and i. The property line markers are maintained in good repair.
A copy of this plan should be submitted to: Kris Riddle NCDEQ – Solid Waste Section Asheville Regional Office 2090 US Highway 70 Swannanoa, NC 28778

PARTIAL SITE HISTORY and BACKGROUND:
• The East Burke Municipal Solid Waste (MSW) landfill is a closed, unlined landfill located off of Rhodhiss Road in Burke County. The landfill operated as Burke County’s eastern landfill between 1972 and 1988. MSW landfills that did not receive municipal solid waste after 10/9/91 were closed in accordance with their Permit, the Conditions of their
Permit, and 15A NCAC 13B .0510. • On 6/5/1974 the NC State Board of Health conducted one of the first inspections of the facility.
• On 5/26/81 the Solid and Hazardous Waste Management Branch (Branch) received a “Development Plan and Erosion
Control Measures for the Burke County Landfill, East Burke Site”. • On 7/3/81 the Branch sent a letter to Burke County requesting modifications to the “Development Plan and Erosion
Control Measures for the Burke County Landfill, East Burke Site”.
• On 1/19/82 Burke County submitted a revised “Site Development Plan and Procedures Erosion Control Measures for the Burke County Landfill – East Burke Site” to the Branch.
• On 2/24/82 the Branch approved the revised “Site Development Plan and Procedures Erosion Control Measures for the
Burke County Landfill – East Burke Site”. • On 9/9/82 Burke County sent the Branch a letter stating that the three required groundwater monitoring wells had been
installed at the Burke County Landfill, East Burke Site. • On 4/12/88 the Burke County Landfill, East Burke Site ceased receiving waste. • On 2/17/89 the Solid Waste Branch received a copy of the “Forest Management Plan for the East Burke Landfill”
from Burke County.
• On 8/19/91 in a Solid Waste Section (Section) memorandum it was noted that a final inspection of the East Burke (Rhodhiss) Landfill was conducted on 8/8/91. It was also noted in the memorandum, “that the East Burke Landfill be
approved for closure in accordance with the requirements of Section .0510 of the NC Solid Waste Management Rules”. Burke County Director of Waste Management, Dale Myers, was copied on this memorandum. • On 7/9/92 the Section sent a letter to Burke County regarding “Closure Letter, Burke County Landfill, Permit No. 12-
02”. The Closure Letter acknowledged that the facility had been closed in accordance with the conditions of Rule .0510 and specified the Closure and Post-Closure Conditions required for Burke County, including post-closure necessary
maintenance and water quality monitoring responsibilities.
• On 2/17/94 the Section sent the Burke County Director of Waste Management a letter regarding “Groundwater Contamination at Two of the Closed Burke County Sanitary Landfills (Permits #12-01 and #12-02)”. The letter stated
that groundwater monitoring data collected at the East Burke landfill had revealed elevated indicator parameters, which
suggested the presence of groundwater contamination at the site. The letter requested an additional sampling of the
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.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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groundwater monitoring wells at the site and to establish a surface water monitoring program for any streams in the
vicinity of the landfill facility. The letter requested the samples be analyzed for organic and inorganic constituents listed in Appendix 1 of the Subtitle D rules.
• On 5/31/94 the Section sent the Burke County Director of Waste Management a letter regarding “Groundwater
Contamination at the Kirksey Drive and East Burke Landfills (Permits #12-01 & 12-02)”. The letter discussed the results of the additional samples collected, as requested in the 2/17/94 letter from the Section to Burke County. The
letter requested additional information due to “concerns for public health”. • On 3/8/95 the Section sent the Burke County Director of Waste Management a letter regarding, “The Need for Additional Groundwater Quality Assessment at the Closed Kirksey Drive and East Burke County Sanitary Landfills
(Permits # 12-01 and 12-02)”. The purpose of the letter was “to present the State’s overall performance objectives and to outline the roles of the County and State in pursuing the water quality investigations”.
• On 5/22/96 the Section sent the Burke County Director of Waste Management a letter regarding, “Comments and
Questions Generated During the Review of Burke County’s East Burke Sanitary Landfill Water Quality Assessment Plan Submitted by Joyce Engineering, Inc. (Permit #12-02)”. • On 6/17/96 Joyce Engineering, Inc. submitted to the Section a letter regarding, “Response to Comments on Water
Quality Assessment Plan East Burke Sanitary Landfill (Permit No. 12-02)”. • On 6/25/96 the Section sent the Burke County Director of Waste Management a letter regarding, “Approval of the
Burke County Kirksey Drive and East Burke Sanitary Landfill Water Quality Assessment Plans ((Permit # 12-01 and
12-02)”. • On 5/9/97 the Section received correspondence from Joyce Engineering, Inc. regarding “Water Quality Assessments –
Revised Well Locations East Burke and Kirksey Drive Landfills”.
• On 6/03 & 8/03 Burke County submitted to the Section correspondence titled, “Updates on Groundwater Assessment Activities”.
• On 10/27/06 the Section issued a memorandum to permitted facilities titled, “New Guidelines for Electronic Submittal
of Environmental Monitoring Data”. • On 10/17/07 the Section issued a memorandum to permitted facilities titled, “Environmental Monitoring Data for
North Carolina Solid Waste Management Facilities”. • On 10/23/07 the Section issued a memorandum to permitted facilities titled, “Addendum to October 27, 2006, North Carolina Solid Waste Section Memorandum Regarding New Guidelines for Electronic Submittal of Environmental
Data”.
• On 7/9/10 the Section sent a letter to Burke County General Services Director/County Engineer, Carson Fisher,
regarding “Warning Notice - Environmental Monitoring Deficiencies”. The letter detailed deficiencies in Burke County’s environmental monitoring reporting and submittal requirements.
• On 5/27/11 & 5/23/11 the Section conducted a facility compliance inspection of the Closed East Burke MSW Landfill
12-02. • On 7/25/11 the Section received a response from Burke County General Services Director/County Engineer stating
that Burke County had received the 5/27/11 & 5/23/11 compliance audit and would enlist the assistance of Joyce Engineering to accomplish a majority of the tasks referenced in the compliance inspection. • In July 2012 a “Landfill Gas Monitoring Plan” for the East Burke Landfill was submitted to the Section by Joyce
Engineering, Inc. on behalf of Burke County. • On 8/7/12 the Section approved a “Landfill Gas Monitoring Plan” for the East Burke Landfill.
• In June 2015 Landfill Gas (LFG) Probes (monitoring wells) No.’s GP1-GP6 were installed at the East Burke Landfill.
• On 7/16/15 the Section received the 3rd quarter LFG monitoring well results which revealed methane detected above the Lower Explosive Limit (LEL) in wells GP-1, GP-3, and GP-4.
• On 9/14/15 a “Landfill Gas Remediation Plan” was submitted to the Section by Joyce Engineering, Inc. on behalf of
Burke County, for exceedances of methane gas in three LFG monitoring wells at the facility. • On 9/18/15 the Section approved the “Landfill Gas Remediation Plan”, which included the proposed installation of a
new LFG monitoring well and three passive LFG vents to control the migration of methane gas at the facility.
• On 11/20/15 the Section granted an extension to Burke County for the installation of the LFG vents at the facility. • On 12/7/15 the Section received the 4th quarter LFG monitoring well results which revealed methane detected above
the LEL in wells GP-1, GP-3, and GP-4.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 8
• On 2/19/16 the Section received the 1st quarter LFG monitoring well results which revealed methane detected above
the LEL in wells GP-1, GP-3, and GP-4. • On 5/2/16 groundwater and surface water monitoring was conducted at the East Burke Landfill.
• On 5/19/16 three LFG passive vents were installed at the facility.
• On 5/24/16 the Section received the 2nd quarter LFG monitoring well results which revealed methane detected above the LEL in wells GP-1, GP-3, and GP-4.
• On 6/28/16 LFG monitoring well GP-1B was installed at the facility.
• On 7/21/16 the Section received a “Landfill Gas Remediation Report”, which provided an update on site monitoring and
remediation activities at the site. The report stated that after one year of gas monitoring (four quarterly events) following installation of the vents, Burke County will make an assessment regarding the effectiveness of the passive vents. • On 8/24/16 the Section received the 3rd quarter LFG monitoring well results which revealed methane detected above the
LEL in wells GP-1, GP-3, and GP-4.
• On 8/31/16 the Section received the 3rd quarter monitoring results for the GP-1B LFG monitoring well at the site
which revealed no exceedance of the LEL. (This well had inadvertently not been sampled during the previous 3rd quarter
sampling event.)
• On 12/19/16 the Section received the 4th quarter LFG monitoring well results which revealed methane detected above
the LEL in wells GP-1, GP-3, and GP-4.
• On 2/13/17 the Section received the 1st quarter 2017 LFG monitoring report which revealed methane detected above
the LEL in wells GP-1, GP-3, and GP-4.
ADDITIONAL COMMENTS:
1. Site inspection conducted by Bill Wagner, Environmental Senior Specialist, Solid Waste Section (Retired) on
March 4, 2014, but a report was not sent to the facility. This is the first inspection of this facility by Environmental Senior Specialist, Kris Riddle.
2. Since the last inspection, monitoring and remediation activities have occurred at the site:
- Edge of Waste (EOW) markers have been installed around the entire disposal area.
- Tree removal has occurred for the installation of LFG passive vents and LFG monitoring wells.
- LFG monitoring wells and LFG passive vents have been installed. (See Site History) - Groundwater and surface water monitoring locations are sampled semi-annually.
- LFG monitoring wells at the site are sampled quarterly.
3. Small amounts of waste were observed near the three LFG vent installation areas at the facility. This waste
should be cleaned up and disposed of properly. 4. Areas of ponded water were observed near the landfill gas vent installation areas at the facility. Efforts should
be made to ensure proper drainage in these areas so that no standing water remains on the landfill cap. 5. Ensure that the groundwater monitoring wells are maintained in good repair. 6. Ensure that the landfill gas monitoring wells and passive vents are maintained in good repair.
7. All photographs taken by Kris Riddle on March 2 & 8, 2017.

1. Looking Northeast across Burke County Closed MSW LF #12-02. 2. Looking Southwest across #12-02 towards convenience center and Rhodhiss Road.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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3. Looking Southeast down towards MW-3. Arrows indicate EOW markers.
4. Looking Northeast along eastern edge of
closed LF. Arrows indicate EOW markers.
5. Groundwater Monitoring Well #2. Typical of GW wells on site.
6. Assessment Monitoring Well (AMW) #1.

7. Typical of surface water monitoring location. Tributary
along eastern edge of closed landfill.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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10. Passive Landfill Gas Vent #3. Typical of LFG vents on site.
8. Landfill Gas Monitoring Well #GP-1.
9. LFG Monitoring Well #GP-3. Typical of LFG wells on site.
12. Broken Edge of Waste marker
– northwestern side of site.
13. Ponded water near Passive LFG Vent #1.
11. Typical Edge of Waste marker at site.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Please contact me if you have any questions or concerns regarding this inspection report.

Phone: [phone]

Kris Riddle, Environmental Senior Specialist Division of Waste Management, NC DEQ
Sent on: March 23, 2017 to
Bryan Steen via:
X Email Hand delivery US Mail Certified No. [ _]

Electronic Copies: Jason Watkins, Field Operations Branch Head - Solid Waste Section Deb Aja, Western District Supervisor - Solid Waste Section
Jessica Montie, Compliance Officer - Solid Waste Section
Jaclynne Drummond, Compliance Hydrogeologist - Solid Waste Section Chris Hollifield, General Services Director/County Engineer – Burke County

14. Debris and ponded water near
Passive LFG Vent #3.
15. Close-up of debris near Passive LFG Vent #3.