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HomeMy WebLinkAbout7904_INSP_20180126FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 11 UNIT TYPE: Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: Rockingham Closed MSWLF HHW White goods X Incin T&P X FIRM PERMIT NO.: 7904-MSWLF-1995 CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: 01/26/2018 and 02/01/2018 Date of Last Inspection: 11/09/2017 FACILITY NAME AND ADDRESS: Rockingham County Landfill 281 Shuff Road Madison, NC 27025 GPS COORDINATES: N: 36.36455° W: - 79.84336° FACILITY CONTACT NAME AND PHONE NUMBER: Name: Ronnie Tate, Engineering and Public Utilities Director Telephone: 336-342-8104 (office) – 336-634-7111 (mobile) Email address: rtate@co.rockingham.nc.us FACILITY CONTACT ADDRESS: P. O. Box 132 Wentworth, NC 27375 PARTICIPANTS: Martie Neugent, Landfill Supervisor – Rockingham County (01/26/18 and 02/01/18) Kathryn Jolly, Environmental Compliance Solid Waste Program Manager – Rockingham County (02/01/18 only) Ronnie Tate, Engineering & Public Utilities Director – Rockingham County (02/01/18 only) Larry Frost, Permitting Engineer – Solid Waste Section (01/26/18 only) Ervin Lane, Hydrogeologist – Solid Waste Section (01/26/18 only) Susan Heim, Environmental Senior Specialist, Solid Waste Section (01/26/18 and 02/01/18) STATUS OF PERMIT: 7904-MSWLF: Original Permit to Construct: Issued August 16, 1994 7904-MSWLF: Original Permit to Operate: Issued May 5, 1995 Permit Amendment 1: Issued July 21, 1997 Permit Amendment 2: Issued March 21, 2000 Permit to Operate Phase 2: Issued May 2, 2002 Permit to Construct Phase 3: January 23, 2006 Permit to Operate Phase 3: Issued May 23, 2007 Permit to Operate (Modification of Permitted Side Slopes): Issued April 9, 2009 Permit to Operate (Authorization to Construct Landfill Gas System): Issued April 25, 2011 Permit to Operate Phase 3 Vertical Expansion: Issued August 27, 2013 Permit Expires August 27, 2018; submit permit renewal request by February 27, 2018. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 11 OBSERVED VIOLATIONS: None ADDITIONAL COMMENTS 1. Operations at the facility consist of an active MSW landfill, currently operating in the Phase 3 Vertical Expansion, a scrap tire collection and processing area, white goods collection and processing area, a collection area for compressed gas containers, a convenience center for the drop-off of residential wastes and single stream recyclable materials, an electronics and television collection area, a wood waste collection and processing area, and an inert debris collection area. The site also contains a landfill gas to energy facility, operated by the county, and located adjacent to the leachate pond. 2. A comprehensive inspection of the facility was begun on 01/26/18. A return visit to the facility took place on 02/01/18 to review additional records and to reinspect the working face access road construction and the temporary leachate holding tank located at the French drain. 3. The MSW landfill is permitted to receive waste generated within a 75-mile radius of the facility. Mr. Neugent stated that the county still limits the waste it accepts to that generated within Rockingham County. Records Review: 4. The current Permit to Operate (dated August 27, 2013) and approved Operations Plan (revised August 2012) were available at the landfill office and reviewed on 01/26/18. Potential changes and additions to the current operations plan were discussed in light of the upcoming permit renewal process. Mr. Neugent stated that he would present these points to the consulting engineer prior to the permit renewal request submittal. 5. Tonnage reports for the facility were reviewed for the current fiscal year. Reports for August, September and December were not available for review. In November 2017, a total of 7,775.48 tons of waste were accepted at the facility; and, in October 2017, waste accepted totaled 7,441.00 tons. Mr. Neugent stated that the average tonnage of waste received daily at the facility has remained above 300 tons. 6. Open top scrap tire trailers are removed and replaced as they are filled by the county’s contractor, New River Tire Recycling. For the month of November 2017, records indicated a total of 104.97 tons of scrap tires were collected at the facility. Scrap tire certification forms for the month of January 2018 were available at the scale house for review. The forms appeared to be complete and properly filled out. Mr. Neugent stated that only the certification forms for the current month are kept at the scale house; older records are retained at the governmental center. 7. White goods program records showed a total of 13.30 tons of white goods had been collected at the facility in November 2017, an amount almost identical to the 13.76 tons collected during November 2016. Mr. Neugent stated that white goods tonnage has remained stable and predictable. CFC removal is performed at the facility by Rapid Recovery, Inc. White goods recycling is handled through a contract with Foss Recycling. 8. Mr. Neugent stated that the electronics and television recycling program has continued to experience an increase in amount of materials dropped off at the site by residents. He added that recycling/disposal services are now contracted through Synergy Electronics Recycling. 9. A review of training records and certifications revealed the following personnel with current SWANA certificates: ▪ Facio Visaya, Landfill Operations Specialist – expires 03/24/2018 ▪ Toran Moore, Landfill Operations Specialist – expires 08/10/2019 ▪ Jacob Collins, Landfill Operations Specialist – expires 08/10/2019 ▪ Martie Neugent, Manager of Landfill Operations – expires 05/06//2020 ▪ Kathryn Jolly, Manager of Landfill Operations – expires 07/07/2019 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 Page 3 of 11 ▪ Ronald Tate, Manager of Landfill Operations – expires 04/04//2019 ▪ Edward Shelton, Manager of Landfill Operations – expires 12/03//2018 10. Facility financial assurance has been received by the Solid Waste Section and is currently under review. 11. The facility has a Title V Air Quality Permit (Permit # 10200T02), which was revised on 11/30/17. 12. The facility has a discharge permit to pump and haul leachate to the City of Eden’s waste water collection system in Wentworth from the leachate pond located on the southwest side of the active landfill. A review of the leachate records indicated that 588,900 gallons of leachate had been pumped and hauled to the City of Eden from 1/1/17 through 11/30/17. Records for August and September 2017 were not available for review. Mr. Neugent stated that the leachate pond had been drained down and cleaned in November 2017, and the sediment removed from the pond had been disposed of in the working face. He added that no leachate pumping had been required since that time. 13. The facility is operated under an NC General Storm Water Permit, and is inspected by the Division of Energy, Mining and Land Resources. 14. Copies of groundwater monitoring records were not available at the landfill office for review. However, records found in the Division’s online Laserfiche document storage indicated that semi-annual sampling events are being conducted as required. The latest reports available were from the second sampling event of 2016, which took place 9/27/16 and 10/26/16, and the first sampling event of 2017, which took place 5/22-5/24/17, 5/30/17 and 7/11- 7/12/17. During the overall timeframe represented by these two semi-annual monitoring reports, the facility moved from detection monitoring to assessment monitoring, and the county is working closely with Ervin Lane, Solid Waste Section Hydrogeologist, to determine the source of the exceedances detected in the monitoring network. 15. Landfill gas monitoring records for the facility were also reviewed through the Division’s online Laserfiche document storage system. The latest landfill gas monitoring report, dated 12/29/17, presented data from a sampling event on 12/22/17. Monthly sampling events have continued to be undertaken by the facility to more closely investigate the detection of methane exceedances 16. Monthly inspections of the flare are conducted monthly by the county’s consultant, Joyce Engineering. Records of these monthly inspections covering the period 1/1/17 through 12/31/17 were reviewed and verified. 17. The leachate sumps are inspected semi-annually for the facility by Reynolda Electric. Records indicated that the latest inspection took place on 12/22/17. 18. Random waste screening logs were examined for the current fiscal year. Review of these records showed that random screenings are now conducted twice per week, a frequency which appears to meet and currently exceed the 1% requirement. Mr. Neugent stated that random screening frequency had been increased based on discussion during the 12/13/16 comprehensive inspection. Log sheets appeared to be complete and indicated the disposition of any unacceptable waste found. 19. Please ensure that the facility’s operating record, including all required documentation, is complete and available for review upon request. It is recommended that a cover log be incorporated into the operating record that indicates when and where soil and alternative forms of cover are used at the facility. 20. It is recommended that record keeping procedures set forth in the facility operations plan be reviewed and amended to reflect current procedures and preferences prior to submittal as a part of the permit renewal application. Active MSW Landfill (Phase 3 Vertical Expansion): 21. Current landfill operations were observed to be taking place in the Phase 3 Vertical Expansion. Mr. Neugent stated that remaining capacity in this cell is expected to last for approximately two years. 22. The slopes of the landfill were observed to be much improved by the extensive repair work that had taken place over the past 12 months. 23. Benches had been built into the slopes at several different levels to slow the flow of surface water and prevent erosion. An area on the southwest slope of the landfill near the leachate pond was observed to have developed rills. This area of the side slope had not had a bench installed. A similar situation was observed on the slope adjacent to the working face, where erosion rills had also begun to develop. Mr. Frost advised the use of an interim protection, such as hydro-mulch, that would help to temporarily stabilize the slopes until additional soil cover could be applied and reseeding could take place. Please ensure that measures are taken to stop erosion on the side slopes of the active landfill, including temporary measures that can be put into place immediately until permanent repairs and reseeding are possible. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 11 24. Some sedimentation was observed in the perimeter ditch line of the active landfill. Please ensure that sediment is removed from the drainage ditch at the toe of the active landfill. 25. The protection around the stormwater inlet on the southwest side of the landfill appeared to be failing. Screening had buckled and become dislodged, allowing gravel and mud to travel into the inlet structure. Please ensure that maintenance is performed on the inlet structure to protect it from sediment intrusion. 26. Six new passive landfill gas vents had been installed on the western side of the active landfill in December 2017, as specified in the county’s plan to address methane exceedances. Repairs had been made to the landfill cap where it had been disturbed as a result of the vent installations, and those areas appeared to have been stabilized. 27. A new access roadway was under construction just east of the current working face access road. As a result, a large area of the landfill slope had been opened. On 1/26/18, landfill staff were observed removing waste, especially large items, from the construction area to the working face and reshaping the contours of the landfill to support the new roadway. The extent of the area of uncovered waste was a concern. However, following the inspection, Mr. Neugent provided photos that clearly showed the waste had been covered. (See photos below.) 28. The leachate pond was observed to have very little liquid impounded, and the flow from the inlet pipe appeared to be a slow trickle. Mr. Neugent explained that the pond had been drawn down and cleaned in November 2017and the sediment removed to the active landfill for disposal. He stated that leachate accumulation had been minimal since then, and no additional leachate had been hauled away for treatment. The evaporization equipment had been removed from the pond and stored elsewhere. 29. At the top of the active landfill, repairs were observed to be underway. Mulch and soil were stockpiled to be mixed for use as alternative cover, as approved. Mr. Neugent explained that the mulch mixture was helping to stabilize the top of the landfill so that intermediate soil cover could be applied and seeding could take place. Some ponding water was observed in areas of the top where repairs had not yet been completed. Please take immediate steps to ensure that water is not impounded over waste. 30. The working face was inspected and found to be small and well compacted. The compactor operator was working to integrate bulky materials with household garbage to achieve the maximum rate of compaction possible. A loader operator worked continuously to clean up material from the road construction area that had dropped onto the access road and to push it into the working face. 31. No unacceptable waste was identified in the working face. 32. Windblown litter was observed only in the area of the new access road construction, and a litter crew was working to collect it at the time of the inspection. Mr. Neugent stated that the litter crew works Monday through Friday to address windblown trash at the facility. 33. No odor or dust emissions were evident during the inspection. 34. The sediment ponds were in the process of being cleaned. The pond located near the landfill office had been completed, and work had begun on the pond located on the east side of the active landfill. Mr. Neugent stated that he hoped to have the remainder of the work on the ponds completed in the spring. 35. Several groundwater and landfill gas monitoring wells were inspected; each of these was found to be well- maintained, easily accessible and secure. 36. One unmarked, unprotected well was observed in a gravel area east of the scale house. Please provide information about this well, its function and disposition, to the Solid Waste Section. 37. The temporary holding tank, located south of the leachate pond at the French drain, was observed to be floating on its side in stormwater on 01/26/18. During the 2/1/18 site visit, the tank had been righted and placed into crushed concrete to keep it in place and upright. (See photos below.) Mr. Neugent stated that the tank had been intact, with no sign of damage or leakage. It is recommended that the holding tank be inspected daily for leachate accumulation and for being correctly situated. 38. Access roadways are of all-weather construction and in good condition. Repairs and repaving had taken place in the fall of 2017. 39. The facility is protected from unauthorized access by means of a chain link fence secured by a locking gate. Proper signage was observed at the facility entrance. 40. Portions of the eastern slope of the landfill cap were unmowed, with woody vegetation and small trees growing inside the liner. Please ensure that maintenance is performed to protect the integrity of the landfill cap, including mowing, removal of small trees and woody vegetation, and repairs to the disturbed areas. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 11 Other Facility Operations: 41. Wood waste storage and processing, white goods collection, scrap tire collection and inert debris storage are located atop Area IV of the closed landfill unit, north of the active landfill. 42. The wood waste area was observed to be clean, and the stockpile to be a manageable size with adequate access in case of fire or other emergency. No unacceptable waste was found in the stockpile. After the processing and removal of the large wood waste stockpile last fall, required soil cover had been restored to this portion of the closed landfill cap, and seeding had taken place. Most of the area had a well-established vegetative cover, and no ponding water was observed. 43. Processed wood waste is no longer stored atop Area II of the closed landfill unit. Since the removal of the processed wood waste stockpile, this area has been reseeded and a stable vegetative cover was observed. The passive gas vents had been repaired and were observed to be in working order. 44. The scrap tire collection site is adjacent to the wood waste area on the north side. Two open-top trailers were staged next to the loading area, where customers can offload tires directly down into them. Facility staff use a loader or track hoe bucket to compact the tires into the trailers as tightly as possible. Mr. Neugent stated that approximately two trailers are filled with tires weekly at the facility. The scrap tire collection area was clean with adequate space for easy access and unloading. No tires were stored on the ground. 45. White goods are stored on a concrete pad to the north of the scrap tire collection area. Units containing CFCs are separated from non-CFC units and stored upright so that the integrity of gas lines is maintained until evacuation can take place. 46. Inert debris is stored at the northwestern edge of Area IV. The stockpile is large, but neatly maintained, with no unacceptable material observed. Mr. Neugent stated that he was planning to use all of the stockpile in constructing the road base for the new access roadway. 47. A convenience area is operated near the scale house atop Area I of the closed landfill unit. The convenience site serves as a residential drop-off for small vehicle loads of MSW, residential recyclables, electronics and televisions, used oil, and lead acid batteries. 48. The convenience area appeared to have adequate space for safe ingress, egress and traffic flow, and included concrete pads at the unloading points. The area was clean and well maintained, and staffed with an attendant during hours of operation. 49. Electronics and televisions are collected on a large concrete pad with a covered area where sorted, palletized materials are neatly stored awaiting transport. The adjacent open area serves as an unloading pad for use by the public. This area was observed to be clean and well maintained. 50. A landfill gas extraction plant, operated by the county, is located next to the leachate collection pond. During the time of the inspection, only the flare was in operation. The county is deciding whether to make the repairs necessary for the plant to become operational again. Erosion rills developing on the side slope next to the current working face (Photo taken on 1/26/18 by S. Heim.). FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 11 Erosion and sedimentation can be seen on the southwest slope of the landfill. (Photo above taken on 1/26/18 by S. Heim; photo below taken on 2/1/18 by S. Heim.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 11 Temporary storage tank at French drain seen dislodged and floating (Photo taken on 1/26/18 by S. Heim.). Holding tank righted and stabilized (Photo taken 2/1/18 by S. Heim.). FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 11 Sediment intrusion into inlet (Photo taken on 1/26/18 by S. Heim.). Failure of inlet protection on the upslope side and at the drainage ditch (Photo taken on 1/26/18 by S. Heim.). FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 11 Woody vegetation and small pine trees growing on the slopes of the landfill (Both photos taken on 1/26/18 by S. Heim.). FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 11 Uncovered waste resulting from new access roadway construction on active landfill (background) with working face (foreground). (Photo taken 1-26- 18 by S. Heim.) All waste covered in area of new access roadway construction. (Photo provided by M. Neugent on 1/27/18.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 11 Please contact me if you have any questions or concerns regarding this inspection report. __________________________________________ Phone: 336-776-9672 Susan Heim Environmental Senior Specialist Regional Representative Sent on: February 8, 2018 to Ronnie Tate, Rockingham Co. X Email Hand delivery US Mail Certified No. Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Deb Aja, Western District Supervisor – Solid Waste Section Ervin Lane, Hydrogeologist – Solid Waste Section Larry Frost, Permit Engineer – Solid Waste Section Kathryn Jolly, Solid Waste Program Manager – Rockingham County Martie Neugent, Landfill Supervisor – Rockingham County