Need to return call by / at/between and . Signature: ___________________________ 

Project No.: 0172.07.005.504 DISTRIBUTION 

Page _1_ of __1_

Project Name: 304(m) Annual Review 

TELEPHONE CALL RECORD 

 Outgoing Call

Date: 3/17/2010 Time: 10:30 am EST 

Company Name: Republic Services 

Contact Name: Mike Olds 

Phone No.: 859-806-3824 

Name: Elizabeth Sabol Eastern Research Group

GENERAL SUBJECT : Mercury concentrations reported to DMR in 2008 

 

TOPICS DISCUSSED AND ACTION TAKEN 

I called Jory Becker on Wednesday, March 17, 2010 at 10:30 am to discuss DMR data submitted by Valley 

View Landfill (KY0090794). I provided Mr. Becker a brief review of the 304(m) project and how we obtain the 

DMR data. I asked him if he could provide information on the flows. Mr. Becker said that the mercury 

concentrations reported for this facility matched the submitted DMR report. Mr. Becker further explained that 

KY sends print outs of the previous DMR data from PCS to the facilities to mark-up hard copy. Then the data is 

entered exactly as written using double-key entry. He explained that errors in the data were likely not data entry 

errors, but errors on the facility’s side. I asked Mr. Becker if the permit limit for mercury was available. He 

stated that he did not have the permit on record; however, supplied me with the listed consultant contact who 

submitted the DMR. 

I called Chip Simmons on Thursday, March 18, 2010 at 1:00 pm to discuss the mercury concentrations 

submitted to DMR in 2008. Mr. Simmons provided Mike Olds’ contact information and suggested that e-mail 

would be the best opportunity to contact him. 

I e-mailed Mr. Olds on Friday, March 19, 2010. Mr. Olds called me on Monday, March 22, 2010 to confirm the 

information requested in the e-mail. Please find all e-mails and supporting documentation attached. 
From: "BILL F. KNARR" <BKNARR@kenvirons.com> 

To: "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 

CC: <molds@republicservices.com> 

Date: 11/1/2010 9:53 AM 

Subject: Re: Valley View Landfill - Mercury Discharges DMR 2008 

Ms. Sabol, 

I have obtained permission from Valley View Landfill for you to use the information regarding the mercury non detect values and data entry 

errors. You may ignore the disclaimer on the email.

If you should have any questions please let me know. 

Bill Knarr 

Associate 

Kenvirons, Inc. 

452 Versailles Rd. 

Frankfort, Kentucky 40601 

502-695-4357 

502-695-4363 FAX 

502-682-2105 Cell 

bknarr@kenvirons.com 

www.kenvirons.com 

>>> "Elizabeth Sabol" <Elizabeth.Sabol@erg.com> 10/29/2010 10:06 AM >>> 

Mr. Knarr, 

 

Thanks again for the data you provided. EPA would like to include these data as part of their public docket, to show why they adjusted the 

discharged pounds of mercury based on non-detect values and data entry error. The public docket is available at http://www.regulations.gov, 

Docket ID EPA-HQ-OW-2008-0517. We have included this type of information in the docket in the past; however, this data transmittal included 

an auto-disclaimer at the end of this e-mail. 

 

In order to do include the updated Mercury information for Valley View Landfill that you provided in the public docket, we would need your 

permission to ignore the auto-disclaimer generated at the bottom of this e-mail: 

 

"Attention: This email message is intended solely for the primary addressee(s) named and may contain information that is confidential, 

proprietary and/or legally privileged. If you are not the intended recipient please delete the message and notify the sender. Any views or opinions 

presented are solely those of the author." 

Please reply to this e-mail to let us know if it is ok to include the information in EPA's public docket. 

 

Thanks, 

Elizabeth 

 

 

 

Elizabeth A. Sabol 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

elizabeth.sabol@erg.com 

Phone:703-633-1659 

>>> "BILL F. KNARR" <BKNARR@kenvirons.com> 3/23/2010 7:07 AM >>> 

Ms. Sabol, 

I am responding to your email dated March 19, 2010 to Mr. Mike Olds regarding the Valley View Landfill DMR's from the 1st quarter, 2008 for 

Discharge 004 and for the 1st semi annual for Discharge 001. 

I work for the consulting firm which completed the DMR's that you have questions about. Mr. Olds authorized me to respond to your email. 

Listed below are the answers to your questions listed in the order that you had them in your email. 

1. The 1st quarter, 2008 DMR has a typo on Discharge 004 for Mercury. The reported value of 40. mg/l is incorrect. The correct result is 

<0.0002 mg/l. The 40 is the volume in ml used to digest the sample. Attached you will find the corrected DMR. 

The 1st semi annual, 2008 DMR has a typo on Discharge 001 for Mercury. The reported value of 40. mg/l is incorrect. The correct result is 

<0.0002 mg/l. The 40 is the volume in ml used to digest the sample. Attached you will find the corrected DMR. 

2. There are no permit limits for Mercury, it is "report only" 
3. Yes, as stated in No. 1, the results were below detection limit. 

Please note, I attached the entire set of March and June 2008 DMR's. The sheets you had in question have been corrected. 

Please let me know if you have any questions or comments. 

Bill Knarr 

Associate 

Kenvirons, Inc. 

452 Versailles Rd. 

Frankfort, Kentucky 40601 

502-695-4357 

502-695-4363 FAX 

502-682-2105 Cell 

bknarr@kenvirons.com 

www.kenvirons.com 

Attention: This email message is intended solely for the primary addressee(s) named and may contain information that is confidential, proprietary 

and/or legally privileged. If you are not the intended recipient please delete the message and notify the sender. Any views or opinions presented 

are solely those of the author. 

Attention: This email message is intended solely for the primary addressee(s) 

named and may contain information that is confidential, proprietary and/or 

legally privileged. If you are not the intended recipient please delete the 

message and notify the sender. Any views or opinions presented are solely those 

of the author. 

Attention: This email message is intended solely for the primary addressee(s) named and may contain information that is confidential, proprietary 

and/or legally privileged. If you are not the intended recipient please delete the message and notify the sender. Any views or opinions presented 

are solely those of the author. 

Attention: This email message is intended solely for the primary addressee(s) 

named and may contain information that is confidential, proprietary and/or 

legally privileged. If you are not the intended recipient please delete the 

message and notify the sender. Any views or opinions presented are solely those 

of the author. 
From: Elizabeth Sabol 

To: molds@republicservices.com 

CC: Codding, Eleanor; Wolford, Jessica; swietlik.william@epa.gov 

Date: 3/19/2010 11:31 AM 

Subject: Valley View Landfill - Mercury Discharges DMR 2008

Dear Mr. Olds, 

 

I am contacting you regarding information submitted in the Valley View Landfill (KY0090794) 2008 discharge monitoring reports. 

Specifically, I would like to check on a possible units error in the DMR data. I have been in contact with the Kentucky permitting 

authority and Mr. Chip Simmons, who suggested I contact you to obtain the information we are looking for. I work for Eastern 

Research Group, Inc. (ERG), and am contacting you on behalf of EPA under EPA Contract No. 68-C-02-095. EPA would like to 

determine the accuracy of mercury discharges reported in the Valley View Landfill 2008 discharge monitoring reports. Here is some 

background on what the information is used for. 

 

EPA reviews publicly-available DMR data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA 

requires EPA to annually review and, if appropriate, revise its water pollution control technology-based regulations, called “effluent 

limitations guidelines” or "effluent guidelines,” that limit the discharge of pollutants to waters of the U.S. from various categories of 

industrial facilities. EPA is currently conducting its 2010 annual review of existing effluent guidelines and potential industrial 

guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further information). EPA will discuss this 

review and the results in its 2010 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in December 

2010. As part of the 2010 annual review, EPA is evaluating the data you reported in your discharge monitoring reports in 2008 and 

needs further information to complete the review. EPA is also contacting POTWs, permitting authorities, and other facilities to 

verify similar information. 

 

We would like to obtain additional information on the mercury concentration for Outfalls 001 and 004 you reported for December 

2008: 

 

1. Are the reported mercury concentration values and units correct for Outfalls 001 and 004 (see below for a list of what is in the 

DMR data)? 

2. What is the current permit limit (including units) for mercury for this facility? 

3. Were any of the 2008 concentrations below the detection limit? 

 

The data we have currently show: 

- DSCH 001: 40 mg/L reported June 30, 2008 

- DSCH 004: 40mg/L reported March 31, 1008. 

- The rest of the data, for all dates and outfalls, show <0.0002 mg/L. 

 

We appreciate your help in confirming if the above data are accurate, or if there is a units error in the DMR data. 

 

If you have any questions regarding this request, please call me at (703) 633-1659. If you would like to speak directly with EPA 

regarding this request, you can contact William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone at (202) 

566-1129 or by email: swietlik.william@epa.gov. 

 

Thanks, 

 

Elizabeth Sabol 

 

Elizabeth A. Sabol 

Environmental Engineer 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

elizabeth.sabol@erg.com 

Phone:703-633-1659 
Name: 

Address: 

Facility: Location: YEAR MO DAY YEAR MO DAY NOTE: Read instrucATTN: FROM 08 01 01 TO 08 03 31

NO.

EX

Average Units Maximum Units

SAMPLE 

MEASUREMENT ******   <0.020 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT ** ****   <0.0050 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT ** ****   <0.010 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT ** ****   <0.010 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT ** ****   <0.0002 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT

PERMIT 

REQUIREMENT

SAMPLE 

MEASUREMENT

PERMIT 

REQUIREMENT

502

AREA N

DOW DMR-01 2/88 

NAME/TITLE PRINCIPAL EXECUTIVE OFFICERMERCURY TOTAL RECOVERABLE

71901 1 0 0EFFLUENT GROSS VALUE

LEAD TOTAL RECOVERABLE

01114 1 0 0EFFLUENT GROSS VALUE

COPPER TOTAL RECOVERABLE

01119 1 0 0EFFLUENT GROSS VALUE

** **********

KY0090794

******

ZINC TOTAL RECOVERABLE

01094 1 0 0EFFLUENT GROSS VALUE

CADMIUM TOTAL RECOVERABLE

01113 1 0 0EFFLUENT GROSS VALUE

004 2

************

****** ************

************************************

******************************

******************************************

****** ******************

VALLEY VIEW LANDFILLSULPHUR, KY 40070Daniel Jansen, Compliance Mgr.

Maximum Minimum Average

QUANTITY OR LOADING QUALITY OR CONCENTRATION

TELEPH

THIS COPY TO APPROPRIATE REGIONA

 SIGNATURE OF PRINCIPAL EXECUTIVE

 OFFICER OR AUTHORIZED AGENT TYPED OR PRINTED

THIS COPY TO DIVISION OF WATER-CENTRAL OFFICE

64

COMMENT AND EXPLANATION OF ANY VIOLATIONS 

DANIEL JANSEN COMPLIANCE MANAGER

KENTUCKY POLLUTANT DISCHARGE ELIMINATION SYSTEM (KPDES) 

DISCHARGE MONITORING REPORT (DMR)

 PERMIT NUMBER DISCHARGE NUMBER

MONITORING PERIOD

PERMITTEE NAME/ADDRESS:

PARAMETER

VALLEY VIEW LANDFILLC/O KENVIRONS, INC.452 VERSAILLES RDFRANKFORT, KY 40601

I CERTIFY UNDER PENALTY OF LAW THAT I HAVE PERSONALLY EXAMINED AND AM FAMILIAR WITH THE

INFORMATION SUBMITTED HEREIN AND BASED ON MY INQUIRY OF THOSE INDIVIDUALS IMMEDIATELYRESPONSIBLE FOR OBTAINING THE INFORMATION, I BELIEVE THE SUBMITTED INFORMATION IS TRUE,ACCURATE AND COMPLETE. I AM AWARE THAT THERE ARE SIGNIFICANT PENALTIES FOR SUBMITTINGFALSE INFORMATION INCLUDING THE POSSIBILITY OF FINE AND IMPRISONMENT. SEE 401 KAR 5:065 ANDKRS 224.994. (Penalties under these statutes may include fines up to $25,000per day of violation or by imprisonmentfor not more than one year, or by both).
Name: 

Address: 

Facility: Location: YEAR MO DAY YEAR MO DAY NOTE: Read instrucATTN: FROM 08 01 01 TO 08 06 30

NO.

EX

Average Units Maximum Units

SAMPLE 

MEASUREMENT ******   0.020 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT ** ****   <0.0050 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT ** ****   <0.010 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT ** ****   <0.010 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT ** ****   <0.0002 (19) 0

PERMIT 

REQUIREMENT ** ****  

REPORT 

DAILY MX MG/L

SAMPLE 

MEASUREMENT

PERMIT 

REQUIREMENT

SAMPLE 

MEASUREMENT

PERMIT 

REQUIREMENT

502

AREA N

DOW DMR-01 2/88 

01114 1 0 0EFFLUENT GROSS VALUE

COPPER TOTAL RECOVERABLE

01119 1 0 0EFFLUENT GROSS VALUE

** ****

ZINC TOTAL RECOVERABLE

01094 1 0 0EFFLUENT GROSS VALUE

CADMIUM TOTAL RECOVERABLE

01113 1 0 0EFFLUENT GROSS VALUE

LEAD TOTAL RECOVERABLENAME/TITLE PRINCIPAL EXECUTIVE OFFICER

DANIEL JANSEN COMPLIANCE MANAGER

MERCURY TOTAL RECOVERABLE

71901 1 0 0EFFLUENT GROSS VALUE

001 1

************

****** ******

MONITORING PERIOD

****** ******

******************

KY0090794

************************

******

******

******************

****** ************************

******

************************ ******

Daniel Jansen, Compliance Mgr.

Maximum Minimum Average

QUANTITY OR LOADING QUALITY OR CONCENTRATION

TELEPH

THIS COPY TO APPROPRIATE REGIONA

 SIGNATURE OF PRINCIPAL EXECUTIVE

 OFFICER OR AUTHORIZED AGENT TYPED OR PRINTED

THIS COPY TO DIVISION OF WATER-CENTRAL OFFICE

64

COMMENT AND EXPLANATION OF ANY VIOLATIONS 

KENTUCKY POLLUTANT DISCHARGE ELIMINATION SYSTEM (KPDES) 

DISCHARGE MONITORING REPORT (DMR)

 PERMIT NUMBER DISCHARGE NUMBER

PERMITTEE NAME/ADDRESS:

PARAMETER

VALLEY VIEW LANDFILLC/O KENVIRONS, INC.452 VERSAILLES RDFRANKFORT, KY 40601VALLEY VIEW LANDFILLSULPHUR, KY 40070

I CERTIFY UNDER PENALTY OF LAW THAT I HAVE PERSONALLY EXAMINED AND AM FAMILIAR WITH THE

INFORMATION SUBMITTED HEREIN AND BASED ON MY INQUIRY OF THOSE INDIVIDUALS IMMEDIATELYRESPONSIBLE FOR OBTAINING THE INFORMATION, I BELIEVE THE SUBMITTED INFORMATION IS TRUE,ACCURATE AND COMPLETE. I AM AWARE THAT THERE ARE SIGNIFICANT PENALTIES FOR SUBMITTINGFALSE INFORMATION INCLUDING THE POSSIBILITY OF FINE AND IMPRISONMENT. SEE 401 KAR 5:065 ANDKRS 224.994. (Penalties under these statutes may include fines up to $25,000per day of violation or by imprisonmentfor not more than one year, or by both).