4117_INSP_20190205

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 9

UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS COUNTY: Guilford
Closed
MSWLF HHW White
goods Incin T&P X FIRM PERMIT NO.: 41-17
CDLF X Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: February 5, 2019 Date of Last Inspection: October 6, 2017

FACILITY NAME AND ADDRESS:
A-1 Sandrock, Inc. C&D Landfill
2091 Bishop Road
Greensboro, NC 27406

GPS COORDINATES:
N: 35.98907 W: -79.84712

FACILITY CONTACT NAME AND PHONE NUMBER:
Ronnie Petty, Owner – A-1 Sandrock, Inc.
w. 336-855-8195
c. 336-207-6052
f. 336-855-8164
[e-mail]

FACILITY CONTACT ADDRESS:
A-1 Sandrock, Inc.
Ronnie Petty, Owner
2091 Bishop Road
Greensboro, NC 27406

PARTICIPANTS:
Chuck Kirchner, Environmental Senior Specialist - Solid Waste Section (SWS)
Ming Chao, P.E., Permitting Engineer, Solid Waste Section (SWS)
Deb Aja, District Supervisor, Solid Waste Section (SWS)
Jason Tarkenton, General Manager – A-l Sandrock, Inc.

STATUS OF PERMIT:
Permit To Operate (PTO) issued October 2, 2017
Life-Of-Site (LOS) Permit
PTO expiration date October 3, 2023 - consistent with Franchise Agreement term

PURPOSE OF SITE VISIT:
Pre-Operational and Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
None

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 9

OBSERVED VIOLATIONS:
1. 15A NCAC 13B .0542(f)(1) states: “Except as provided in Subparagraph (3) of this Paragraph, the owners and
operators of all C&DLF units must cover the solid waste with six inches of earthen material when the waste disposal area
exceeds one-half acre and at least once weekly. Cover must be placed at more frequent intervals if necessary to control
disease vectors, fires, odors, blowing litter, and scavenging.

A-1 Sandrock, Inc. is in violation of 15A NCAC 13B .0542(f)(1) in that an area exposed waste that was observed
adjacent to the access road, near the east side of Cell 3A construction. Facility staff confirmed that this area of
waste was exposed during preliminary grading in Cell 3A and had not been covered at least once weekly.

In addition, waste was exposed at the toe of the landfill slope in the approximate location where Cell 2A and Cell
2B meet on the west side of the landfill. These areas were observed uncovered by Section staff on January 7,
2019 during a site visit pertaining to permit items and facility staff were notified of the need to take corrective
action. The waste observed at the toe of the landfill slope was exposed by pumping stormwater through the area
from the new cell construction.

To achieve compliance with 15A NCAC 13B .0542(f)(1), all exposed waste must be covered with a minimum of
6-inches of earthen material within 7-days of receipt of the Notice of Violation. Areas which will not have
additional wastes placed on them for 12-months or more, but where final termination of disposal operations has
not occurred, shall be covered with a minimum of 1-foot of intermediate cover.

Area of exposed waste on the east side
of Cell 3A area. Photo by Chuck
Kirchner on 2/5/2019.
***Eroded toe of slope and exposed
waste between Cell 2A and Cell 2B.
Photo by Chuck Kirchner on 2/5/2019.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 9

2. 15A NCAC 13B .0542(g)(2) states: “Solid waste must be compacted as densely as practical into cells.”

A-1 Sandrock is in violation of 15A NCAC 13B .0542(g)(2) in that the waste in the lower portion of the active
disposal area was not compacted as densely as practical into cells. The waste could not be properly compacted
due to the slope and drop-off to the new cell construction. Because the waste was not properly compacted it
contributed to windblown litter at the site and the waste had the potential to fall into the new cell construction
area. To achieve compliance A-1 Sandrock must immediately properly compact the waste as densely as
practical into cells.

3. 15A NCAC 13B .0542(g)(3) states: “Appropriate methods such as fencing and diking must be provided within the area
to confine solid waste which is subject to be blown by the wind. At the conclusion of each operating day, all windblown
material resulting from the operation must be collected and disposed of by the owner and operator.”

A-1 Sandrock, Inc. is in violation of 15A NCAC 13B .0542(g)(3) by having excess windblown trash on the slope
and along the toe of the landfill slope in the approximate location where Cell 2A and Cell 2B meet on the west
side of the landfill. This area was observed and discussed between Jason Tarkenton, Certified Landfill Operations
Specialist, A-1 Sandrock, Inc., the facility’s consultant, David Garrett, and Section staff during the January 7,
2019 site visit.

To achieve compliance with 15A NCAC 13B .0542(g)(3) A-1 Sandrock, Inc. must, at the conclusion of each
operating day, collect and dispose of all windblown material resulting from the operation. The large working
face and lack of proper compaction is likely contributing to the generation of windblown litter and must be
addressed.

***See example picture above.

4. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s) shall be considered
to have accepted the conditions of the permit and shall comply with the conditions of the permit.”

Permit to Operate No. 4117, Attachment 1, General Permit Conditions/Information, Part I, General Facility
Permit Condition 6 states in part, “Operation of this solid waste management facility must be in accordance with
the Solid Waste Management Rules, 15A NCAC 13B, Article 9 of the Chapter 130A of the North Carolina
General Statutes (N.C.G.S. 130A-290, et seq.), the conditions contained in this permit, and the approved plan.”

Permit to Operate No. 4117, Attachment 1, General Permit Conditions/Information, Part I, General Facility
Permit Condition 7 states in part, “This permit is issued based on the documents submitted in support of the
Lower section of working face not
properly compacted and has steep slopes.
Photo by Deb Aja on 2/5/2019.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 9

application for permitting the facility including those identified in the ‘List of Documents for the Approved Plan’
which constitute the approved plan for the facility.” Permit to Operate No. 4117, Attachment 1, General Permit
Conditions/Information, Part III, Construction and Demolition Debris Landfill Units (October 2017) lists in part
‘Permit to Operate Application, A-1 Sandrock C&D Landfill, Phase 2A, Solid Waste Permit 41-17-CDLF-2008,’
as one of the documents for the Approved Plan. The approved Permit to Operate Application General Facility
Operations Plan, Section 5.10.1, Inspections and Maintenance states: “All aspects of the facility operation are
subject to the requirements of 15A NCAC 4, the Sedimentation and Erosion Control rules. Runoff measures for
this facility were designed in accordance with this rule and approved by the now NCDEQ Division of Energy,
Minerals and Land Resources, Land Quality Section. Approved S&EC measures shall be installed and
maintained throughout the operational life of the facility and into the post-closure period (see Closure/Post
Closure Plan, Section 7.0). Measures to curtail erosion include vegetative cover and woody mulch as ground
cover. Measures to control sedimentation include stone check dams in surface ditches, sediment traps and basins.
As of March 2013, all exposed soils, regardless of whether they are inside or outside the disposal area, shall be
vegetated or otherwise stabilized within 15 days after any given area is brought to final grade.”

A-1 Sandrock, Inc. is in violation of 15A NCAC 13B .0203(d) and General Facility Permit Condition 6 by failing
to install and maintain adequate sediment control measures per an approved S&EC plan and failure to stabilize
disturbed areas.

5. 15A NCAC 13B .0542(k)(1) states: “Adequate sediment control measures consisting of vegetative cover, materials,
structures or devices must be utilized to prevent sediment from leaving the C&DLF facility.”

A-1 Sandrock, Inc. is in violation of 15A NCAC 13B .0542(k)(1) by failing to install and maintain adequate
sediment control measures sufficient to prevent sediment loss off site. During the inspection it was noted that
sediment left the property and went down to a creek on the east side of the site below the new borrow area and
from the outside ditch line along the east side access road.

6. 15A NCAC 13B .0542(k)(2) states: “Adequate sediment control measures consisting of vegetative cover, materials,
structures or devices must be utilized to prevent excessive on-site erosion of the C&DLF facility or unit.”

A-1 Sandrock, Inc. is in violation of 15A NCAC 13B .0542(k)(2) by failing to install and maintain adequate
sediment control measures and establish grass cover sufficient to prevent excessive on-site erosion. During the
inspection it was noted that sediment rills have formed on several interior slopes, excessive sediment load is in the
interior ditch line and there is excessive erosion along the toe of the slope below Cell 2A.

To achieve compliance with 15A NCAC 13B .0203(d), General Facility Permit Condition 6, 15A NCAC 13B
.0542(k)(1) and 15A NCAC 13B .0542(k)(2):
1. Immediately install erosion control measures sufficient to prevent sediment loss from site below new
borrow/fill area.

2. Ensure all disturbed areas and future proposed disturbed areas on the northeast corner of site are within
an approved S&EC plan limits of disturbance and erosion control measures are installed per the approved
plan. A-1 Sandrock, Inc. must be able to demonstrate compliance with applicable erosion control
regulations.

3. Remove accumulated sediment from ditch line on east side of site and repair and stabilize ditch line.

4. Remove accumulated sediment from basin and ensure discharge pipe is functioning per the S&EC plan
design.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 9

5. Divert interior flow from borrow waste area along east side of access road on east side of site into ditch line
going to sediment basin as discussed in the field. Ensure sediment basin is re-sized if necessary to
accommodate additional drainage area.

6. Repair and stabilize toe of slope below Phase 2A.

7. Stabilize additional borrow/fill area with 2” of mulch or grass cover sufficient to prevent erosion.

8. Repair and stabilize eroded rills on slopes throughout site.

Area at NE corner of borrow/fill area. No East side of borrow/fill area. No defined
diversions or basins in low area. Silt fence diversion berm in this area. No slope
compromised and not toed in. Sediment loss stabilization. Photo by Chuck Kirchner on
was observed in this area. Photo by 2/5/2019.
Chuck Kirchner on 2/5/2019.

View of rills in borrow/fill slopes south of View of sediment load in east side ditch below
phase 3 area. Photo by Chuck Kirchner phase 3 area. Photo by Chuck Kirchner on
on 2/5/2019. 2/5/2019.

7. 15A NCAC 13B .0542(l)(4) states: “Leachate must be contained on-site or treated prior to discharge.”

A-1 Sandrock, Inc. is in violation of 15A NCAC 13B .0542(l)(4) by failing to prevent leachate from leaving the
edge of waste in the approximate location where Cell 2A and Cell 2B meet on the west side of the landfill.
Stormwater was pumped from the new cell construction along the toe of the slope of Cell 2A, exposing waste.
This activity exposed waste, and as pumping activities continued the stormwater that came in contact with waste
was discharged as leachate into the stormwater conveyance ditch.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 9

To achieve compliance with 15A NCAC 13B .0542(l)(4) A-1 Sandrock, Inc. must submit a soil sampling plan
within 10 days of the receipt of this inspection report to Christine Ritter, Hydrogeologist, Environmental
Compliance Branch (919-707-8254 or by email at [e-mail]). On February 7, 2019, Ms. Ritter
emailed Jason Tarkenton guidelines to conduct sampling. Additional measures may be required upon review of
sampling analytical test results.

Possible leachate observed ponded in small area at the
toe of the slope below cell 2A. Photo by
Chuck Kirchner on 2/5/2019.

ADDITIONAL COMMENTS
On February 5, 2019, Chuck Kirchner, Deb Aja and Ming Chao met with Jason Tarkenton to conduct a comprehensive
inspection of the A-1 Sandrock, Inc. C&D Landfill on Bishop Road in Greensboro, Guilford County.

1. The facility is a construction and demolition debris (C&D) landfill with a C&D treatment and processing (T&P)
operation.
2. The facility is in operation Monday through Friday 7:00 am – 5:00 pm and Saturday as needed.
3. The facility permit, site plan, and operations plan were discussed.
4. The facility permit approves the operation of C&D landfill Phases 1 and 2 and the C&D T&P [sorting and
recycling] operation. Plans for Phase 3A are currently under review.
5. The facility is accepting C&D in the south side of Phase 1.
6. Phase 1 is covered with soil and contains vegetative ground cover on the north and east side of phase.
7. The facility service area is located up to 50 miles from the landfill. Counties within the fifty-mile radius include:
Alamance, Cabarrus, Caswell, Chatham, Davidson, Davie, Durham, Forsyth, Guilford, Lee, Montgomery, Moore,
Orange, Person, Randolph, Rockingham, Rowan, Stanly, Stokes, Surry, and Yadkin.
8. The facility is permitted to receive C&D, inert debris, land clearing debris (LCD), and (used) asphalt.
9. The facility shall not accept yard trash for disposal.

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 7 of 9

RECORDS REVIEW

10. The following are facility certified personnel:
a. Ronald Petty, Certified Manager of Landfill Operations, No. 1383051, exp. 06/10/20
b. Jason Tarkenton, Certified Landfill Operations Specialist, No. LF-2014017, exp. 06/13/20
c. Andy Tucker, Certified Landfill Operations Specialist, No. LF-2005090, expired on 02/28/18. Please
provide updated training certificate once this has been renewed. Please ensure that a certified operator is
on site at all times during hours of operation.
d. Daniel Bowland, Certified Landfill Operations Specialist, No. LF-2017044, exp. 09/08/20
11. The facility is required to conduct a minimum of three waste screenings a week. The facility currently conducts
one waste screening per day. Waste screening records were observed for September 2017 through December
2018.
12. The facility maintains a record of the amount of material received. The average amount of C&D received for
disposal from July 2018 through December 2018 is 9,443.70 tons per month and the average amount of recycled
materials, which included ferrous scrap, concrete, wood and LCD, during the same time is 1,654.49 tons per
month.
13. The facility is crushing concrete on an ongoing basis.
14. It has been stated that the facility reclaims > 10 percent of the material received.
15. The facility maintains a weekly soil cover log. Records were observed for January 5, 2018 through May 24, 2018.
16. The facility annual report (FAR) was received by the SWS dated August 1, 2018. Tonnage of C&D received July
2017 through June 2018 is 117,283.15. Tonnage of recovered material (metal, pallets, and concrete) during the
same time is 31,812.32.

OPERATIONS INSPECTION of the FACILITY:

17. It appears new borrow/fill area is outside of what was covered by NCDEQ Division of Energy, Minerals and Land
Resources, Land Quality Section S&EC plan. Please provide a copy of the current S&EC plan covering this
area.
18. The recovered material storage area for concrete is adjacent to the scale house. The LCD and clean wood are
stored in Storage Area B & C.
19. Mr. Tarkenton stated that the facility does not operate the treatment and processing (T&P) picking line at this
time.
20. Processed and unprocessed clean wood, and LCID were observed. The material was in compact piles and
windrows.
21. High nitrogen to carbon ratio yard trash shall not be accepted as a recovered material.
22. No grinding of wastes shall take place in the rain.
23. Fire lanes were maintained between stockpiles of combustible material.
24. The facility shall cover solid waste with six-inches of soil when the waste disposal area exceeds one-half acre and
at least once weekly.
25. Mr. Tarkenton stated that the facility does not use alternative daily cover.
26. The working face size needs to be monitored and was too steep at the bottom. Please see the Observed Violations
section of this report.
27. On February 14, 2019, Jason Tarkenton emailed photographs and a narrative describing corrective measures taken
by the facility. A follow-up inspection will be conducted.
28. The landfill footprint is designated by edge of waste markers.
29. The facility is currently placing waste in Cell 1C, and currently has Phase 3A under review and awaiting
permitting approval.
30. Mr. Tarkenton stated that when material known to contain asbestos is received, it is brought to a previously GPS
designated area, placed in a pre-dug hole, and covered with soil. Asbestos disposal records observed for 2018
noted four separate areas for disposal.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 9

31. The facility maintains semiannual groundwater and surface water monitoring test records submitted by SCS
Engineers, PC and conducted by Pace Analytical. Records for May 2017, July 2018 and November 2018 were
observed.
32. The facility conducts landfill gas monitoring quarterly using a bar hole punch. Records were observed for 2017
and 2018.
33. The facility maintains quarterly methane and hydrogen sulfide monitoring records. Landfill gas monitoring is
conducted by Pace Analytical. Monitoring records were observed for 2017 and 2018. Zero percent methane and
zero percent hydrogen sulfide were still noted.
34. A new Environmental Monitoring Plan is currently underway. Possible leachate was observed on site during this
inspection. For additional discussion contact Christine Ritter, SWS – Permitting Hydrogeologist, at 919-707-
8254.

Possible leachate coming out from natural ground View of possible leachate from above. Photo by
below RCP pipe. Photo by Chuck Kirchner on 2/5/2019. Chuck Kirchner on 2/5/2019.

35. Ensure a readily accessible unobstructed path to each groundwater monitoring well and landfill gas bar hole punch
test location is maintained.

SUPPORTING COMMENTS:
36. The facility obtains soil from operations conducted on site.
37. Ensure erosion rills on the landfill cap are repaired accordingly.
38. Windblown materials shall be collected by the end of each operating day.
39. The facility has a 2,200-gallon water truck which can be used for dust control.
40. The Pinecroft Sedgefield Fire District can be contacted to address an emergency at the facility.
41. The facility has all-weather access roads.
42. The facility is secured by a locked gate.
43. The facility has a proper sign.
44. The PTO expiration date is October 3, 2023, consistent with the Franchise Agreement term.
45. The PTO expiration can be adjusted when a new Franchise Agreement is obtained.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 9

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

Phone: [phone]

Chuck Kirchner
Environmental Senior Specialist
Regional Representative
Sent on: February 20, 2019 X Email Hand delivery US Mail Certified No. [ X_]
Copies: Deb Aja, Western District Supervisor - SWS
Ming-Tai Chao, Environmental Engineer – SWS
Christine Ritter, Permitting Hydrogeologist – SWS
Jason Tarkenton, General Manager – A-l Sandrock, Inc. (c. 336-382-9707, [e-mail])
Matthew E. Gantt, P.E., Regional Engineer, DEMLR