# Need to return call by / at/between and . Signature: ___________________________ Project No.: 0172.07.005.504 DISTRIBUTION

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# 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 DM R 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 revi ew of the 304(m) project and how we obtain the

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

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

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

entered exactly as written using double-key entry. He expla ined 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. H e

stated that he did not have the permit on record; howeve r, 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’ cont act 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 call ed me on Monday, March 22, 2010 to confirm the

information requested in the e-mail. Please find all e-m ails 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 Landfil l for you to use the information regarding the merc ury 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 l ike to include these data as part of their public d ocket, to show why they adjusted the

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

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

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

In order to do include the updated Mercury informat ion for Valley View Landfill that you provided in t he 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 f or the primary addressee(s) named and may contain i nformation that is confidential,

proprietary and/or legally privileged. If you are n ot 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 dock et.

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> 3/23/201 0 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 Disch arge 001.

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

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

1. The 1st quarter, 2008 DMR has a typo on Discharg e 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 di gest the sample. Attached you will find the correct ed DMR.

The 1st semi annual, 2008 DMR has a typo on Dischar ge 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 di gest the sample. Attached you will find the correct ed DMR.

2. There are no permit limits for Mercury, it is "r eport 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 ha ve been corrected.

Please let me know if you have any questions or com ments.

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 fo r the primary addressee(s) named and may contain in formation that is confidential, proprietary

and/or legally privileged. If you are not the inten ded 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 fo r the primary addressee(s)

named and may contain information that is confident ial, proprietary and/or

legally privileged. If you are not the intended rec ipient please delete the

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

of the author.

Attention: This email message is intended solely fo r the primary addressee(s) named and may contain in formation that is confidential, proprietary

and/or legally privileged. If you are not the inten ded 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 fo r the primary addressee(s)

named and may contain information that is confident ial, proprietary and/or

legally privileged. If you are not the intended rec ipient please delete the

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

of the author.

# From: Elizabeth Sabol

To: molds@republicservices.com

CC: Codding, Eleanor; Wolford, Jessica; swietlik.wil liam@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 disch arge monitoring reports.

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

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

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

determine the accuracy of mercury discharges report ed in the Valley View Landfill 2008 discharge monit oring 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 C lean Water Act. The CWA

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

limitations guidelines” or "effluent guidelines,” t hat 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 guidel ines 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 Guideli nes Program Plan scheduled for publication in the F ederal Register in December

2010. As part of the 2010 annual review, EPA is eva luating the data you reported in your discharge mon itoring reports in 2008 and

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

verify similar information.

We would like to obtain additional information on t he mercury concentration for Outfalls 001 and 004 y ou reported for December

2008:

1. Are the reported mercury concentration values an d 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 unit s) for mercury for this facility?

3. Were any of the 2008 concentrations below the de tection 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, s how <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, p lease 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 Analy sis 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:703-633-1659MINORName:(SUBR FL)TRIMBAddress:F - FINALSTORMWATER RUNOFFSTORMWATERFacility:*** NO DISCHARGE ***Location:YEAR MO DAY YEAR MO DAY NOTE: Read instructions before completing this form.ATTN:FROM08 0101TO08 03 31NO.EXAverage Units Maximum UnitsSAMPLEMEASUREMENT******  <0.020(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENT** ****  <0.0050(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENT** ****  <0.010(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENT** ****  <0.010(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENT** ****  <0.0002(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENTPERMITREQUIREMENTSAMPLEMEASUREMENTPERMITREQUIREMENT502AREA NUMBER YEAR MO DAYDOW DMR-01 2/88PAGE 2 OF 2NAME/TITLE PRINCIPAL EXECUTIVE OFFICERMERCURYTOTAL RECOVERABLE71901 1 0 0EFFLUENT GROSS VALUELEADTOTAL RECOVERABLE01114 1 0 0EFFLUENT GROSS VALUECOPPERTOTAL RECOVERABLE01119 1 0 0EFFLUENT GROSS VALUE** **********KY0090794******ZINCTOTAL RECOVERABLE01094 1 0 0EFFLUENT GROSS VALUECADMIUMTOTAL RECOVERABLE01113 1 0 0EFFLUENT GROSS VALUE004 2****************** ****************************************************************************************************************************** ******************QTRLY GRABQTRLY GRABQTRLYQTRLYQTRLYQTRLYSAMPLETYPEFREQUENCYOFANALYSISVALLEY VIEW LANDFILLSULPHUR, KY 40070Daniel Jansen, Compliance Mgr.AverageMinimumMaximumQUANTITY OR LOADING QUALITY OR CONCENTRATIONGRABGRABGRABGRABGRABGRABGRABGRABTELEPHONE DATETHIS COPY TO APPROPRIATE REGIONAL OFFICESIGNATURE OF PRINCIPAL EXECUTIVEOFFICER OR AUTHORIZED AGENTTYPED OR PRINTEDTHIS COPY TO DIVISION OF WATER-CENTRAL OFFICE643-2976COMMENT AND EXPLANATION OF ANY VIOLATIONSDANIEL JANSENCOMPLIANCE MANAGERKENTUCKY POLLUTANT DISCHARGE ELIMINATION SYSTEM(KPDES)QTRLYQTRLYDISCHARGE MONITORING REPORT(DMR)PERMIT NUMBER DISCHARGE NUMBERQTRLYMONITORING PERIODQTRLYPERMITTEE NAME/ADDRESS:PARAMETERVALLEY VIEW LANDFILLC/O KENVIRONS, INC.452 VERSAILLES RDFRANKFORT, KY 40601I CERTIFY UNDER PENALTY OF LAW THAT I HAVE PERSONALLY EXAMINED AND AM FAMILIAR WITH THEINFORMATION 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 SIGNIFICANTPENALTIES 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).MINORName:(SUBR FL)TRIMBAddress:F - FINALSTORMWATER RUNOFFSTORMWATERFacility:*** NO DISCHARGE ***Location:YEAR MO DAY YEAR MO DAY NOTE: Read instructions before completing this form.ATTN:FROM08 0101TO08 06 30NO.EXAverage Units Maximum UnitsSAMPLEMEASUREMENT******  0.020(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENT** ****  <0.0050(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENT** ****  <0.010(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENT** ****  <0.010(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENT** ****  <0.0002(19)0PERMITREQUIREMENT** ****  REPORTDAILY MXMG/LSAMPLEMEASUREMENTPERMITREQUIREMENTSAMPLEMEASUREMENTPERMITREQUIREMENT502AREA NUMBER YEAR MO DAYDOW DMR-01 2/88PAGE 2 OF 201114 1 0 0EFFLUENT GROSS VALUECOPPERTOTAL RECOVERABLE01119 1 0 0EFFLUENT GROSS VALUE** ****ZINCTOTAL RECOVERABLE01094 1 0 0EFFLUENT GROSS VALUECADMIUMTOTAL RECOVERABLE01113 1 0 0EFFLUENT GROSS VALUELEADTOTAL RECOVERABLENAME/TITLE PRINCIPAL EXECUTIVE OFFICERDANIEL JANSENCOMPLIANCE MANAGERMERCURYTOTAL RECOVERABLE71901 1 0 0EFFLUENT GROSS VALUE001 1****************** ******MONITORING PERIOD****** ************************KY0090794************************************************************ ************************SEMIANNUALSEMIANNUALSEMIANNUALSEMIANNUALSEMIANNUAL******GRABSEMIANNUALGRABSEMIANNUALGRAB************************ ******SAMPLETYPEFREQUENCYOFANALYSISDaniel Jansen, Compliance Mgr.AverageMinimumMaximumQUANTITY OR LOADING QUALITY OR CONCENTRATIONGRABGRABGRABGRABGRABGRABGRABTELEPHONE DATETHIS COPY TO APPROPRIATE REGIONAL OFFICESIGNATURE OF PRINCIPAL EXECUTIVEOFFICER OR AUTHORIZED AGENTTYPED OR PRINTEDTHIS COPY TO DIVISION OF WATER-CENTRAL OFFICE643-2976COMMENT AND EXPLANATION OF ANY VIOLATIONSKENTUCKY POLLUTANT DISCHARGE ELIMINATION SYSTEM(KPDES)SEMIANNUALSEMIANNUALDISCHARGE MONITORING REPORT(DMR)PERMIT NUMBER DISCHARGE NUMBERSEMIANNUALPERMITTEE NAME/ADDRESS:PARAMETERVALLEY VIEW LANDFILLC/O KENVIRONS, INC.452 VERSAILLES RDFRANKFORT, KY 40601VALLEY VIEW LANDFILLSULPHUR, KY 40070I CERTIFY UNDER PENALTY OF LAW THAT I HAVE PERSONALLY EXAMINED AND AM FAMILIAR WITH THEINFORMATION 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 SIGNIFICANTPENALTIES 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).