3003_RES_20170913

State of North Carolina | Environmental Quality | Waste Management
217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919 707 8200
ROY COOPER
Governor

MICHAEL S. REGAN
Secretary

MICHAEL SCOTT
Director

September 13, 2017

Mr. John Eller
123 South Main Street
Mocksville, NC 27028

SUBJECT: Notice of Deficiency issued March 24, 2017
Closed Davie County MSW Landfill – 30-01
Closed Davie County C & D Landfill – 30-03
Davie County

Dear Mr. Eller:

On January 31, 2017, Kim Sue and Charles Gerstell, representing the State of North Carolina,
Division of Waste Management Solid Waste Section (Section), inspected the above referenced
facilities for compliance with North Carolina solid waste statutes and rules. Davie County was in
violation of 15A NCAC 13B .0510(c) as a result of failing to meet the design standards for landfill
gas found in Rule .0503(2)(a) at both the closed Davie County MSW Landfill (Permit No. 30-01)
and the closed Davie County C & D Landfill (Permit No. 30-03). During the inspections, it was
determined that permanent methane monitoring devices were never installed. There were no
records showing that Davie County had performed explosive gas monitoring at the closed
municipal solid waste facility as required in the closure letter dated May 30, 1995 nor records
showing that Davie County had performed explosive gas monitoring at the closed C & D Landfill
as required in Rule 15A NCAC 13B .0503(2)(a).

To achieve compliance, Davie County was required to develop a landfill gas monitoring plan and
submit the plan to Elizabeth Werner, Permitting Hydrogeologist, for review and approval. A
Landfill Gas Monitoring Plan for Davie County MSW Landfill (Permit 30-01) and Davie County C&D
Landfill (Permit 30-03) was submitted to Elizabeth Werner on May 30, 2017 and approved on July
22, 2017. Therefore, this violation is considered resolved.

Davie County was in violation of 15A NCAC 13B .0510(c) as a result of failing to maintain the
integrity and effectiveness of the final cover system and any permanent erosion control devices
at both the closed Davie County MSW Landfill (Permit No. 30-01) and the closed Davie County C
& D Landfill (Permit No. 30-03). During the inspection, trees were observed on both eastern
and western side slopes of the landfill. This issue was addressed in 2003 and 2004. Since that
time edge of waste markers were installed showing that trees are growing on the cap over
waste. Thus, the final cover system was not maintained. This constituted a violation of 15A
NCAC 13B .0510(c).
Davie County MSW & C&D Landfills
RE: Notice of Deficiency issued March 24, 2017
Page 2 of 2
September 13, 2017

To achieve compliance, Davie County was required to develop and submit to the Section a
written maintenance plan which ensures landfill cap integrity. A Post-Closure Maintenance
Plan was submitted on June 23, 2017. A review of the plan was conducted and
recommendations were discussed with S&ME. On August 28, 2017, a revised Post-Closure
Maintenance Plan – Revision 01 was submitted and approved. Therefore, this violation is
considered resolved.

This letter serves to confirm that the requirements of the Notice of Deficiency have been satisfied
and the violation has been corrected. Davie County is encouraged to meet all requirements and
deadlines set forth in the approved Post-Closure Maintenance Plan – Revision 01 to prevent
future enforcement action.

Thank you for your cooperation in this matter. Should you have any questions, please do not
hesitate to contact me at [phone] or [e-mail].

Sincerely,

Kim Sue
Environmental Senior Specialist
Division of Waste Management/Solid Waste Section

copies: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor - Solid Waste Section
Jessica Montie, Compliance Officer - Solid Waste Section
Elizabeth Werner, Permitting Hydrogeologist
Johnny Lambert, Davie County Public Utilities Director