7904_INSP_20190808

oepamnem a� enmmnmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
X
LCID
YW
X
Transfer
Compost
SLAS
COUNTY: Rockingham
MSWLF
PERMIT NO.: 7904
Closed
X
xxW
White
X
Incin
T&P
FMM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
Tire T&P /
X
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: August 8, 2019
FACILITY NAME AND ADDRESS:
Rockingham County Landfill
281 Shuff Road
Madison, NC 27025
GPS COORDINATES: Lat: 36.36455 °
Date of Last Inspection: January 28, 2019
Long: 79.84336 °
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Ronnie Tate, Engineering and Public Utilities Director
Telephone: [phone] (office) — 336-634-7111 (mobile)
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
P. O. Box 132
Wentworth, NC 27375
PARTICIPANTS:
Martie Neugent, Landfill Supervisor — Rockingham County
Kathryn Jolly, Environmental Compliance Solid Waste Program Manager — Rockingham County
Jenny Johnson — LaBella/Joyce Engineering
Mousa Maimoun — LaBella/Joyce Engineering
David Giachini, Permitting Engineer — Solid Waste Section
Jason Watkins, Field Operations Branch Head — Solid Waste Section
Susan Heim, Environmental Senior Specialist — Solid Waste Section
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 Phases 1, 2 and 3 Vertical Expansion: Issued April 12, 2019
Permit to Construct Phase 4 Lateral Expansion: Issued April 12, 2019
PURPOSE OF SITE VISIT:
Partial inspection of landfill operations and to observe status of active construction activities.
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D_EFACILITY COMPLIANCE INSPECTION REPORT
Q�� Division of Waste Management
oeromm�i oRi e.�m�i aim
Solid Waste Section
STATUS OF PAST NOTED VIOLATIONS:
1. RESOLVED: 15A NCAC 13B .1626(11)(c) states, in part: "At the conclusion of each day of operation, all
windblown material resulting from the operation shall be collected and returned to the area by the owner or
operator." Rockingham County was in violation for failing to collect and return all windblown material to the
active landfill at the end of each operating day. During this inspection, windblown litter appeared to be well -
controlled. Therefore, this violation is considered to be resolved.
View of the southwestern side
slope overlooking the leachate
pond. Slopes have been regraded
and covered. Windblown litter is
well -managed.
OBSERVED VIOLATIONS:
None
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.
ADDITIONAL COMMENTS:
Field Inspection:
1. This site visit was made for the purpose of conducting a follow-up field inspection of the facility, and to observe
the ongoing construction of Phase 4 and the partial closure of Phases 1, 2 and 3. No facility operating records
were reviewed.
2. All photos included in this report were taken by Susan Heim during the inspection on August 8, 2019
3. On arrival at the facility, the operations area that includes the wood waste stockpile, tire collection, white goods
collection and inert debris collection was observed. Wood waste had been accumulated into two large piles (see
comment 22); no unacceptable materials were noted in the piles. White goods containing refrigerants had been
staged so that they were upright and spaced for easy access by the contractor that would be performing
refrigerant evacuation.
4. No tire trailers were present onsite upon arrival though one was observed being loaded at the conclusion of the
inspection. A pile of an estimated 1500+ tires was evident on the concrete pad above the trailer parking spots.
Ms. Jolly stated that the contractor is not supplying trailers as needed to handle volume. It should be noted that
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oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
tires must be containerized or covered within 10 days. In the absence of trailers, the facility may have to
determine alternative methods to cover the tires to prevent nuisance conditions, vectors, etc.
5. The northwest slope of the landfill was observed to have been covered with liner material as part of the partial
closure that had been approved for Phases 1, 2 and 3. Mr. Maimoun stated that between 2/3 and 3/4 of the
landfill side slopes would receive final cover. He explained that the closure construction would be more easily
viewed from the top of the landfill.
6. The leachate pond was inspected, and maintenance work performed since the previous inspection on February
19, 2019 was noted. All of the brush and weeds that had been growing up around the perimeter of the pond had
been removed, and the exposed portion of the pond liner had been cleared and cleaned. The liner appeared to be
in good condition. The pond level marker indicated that the pond had at least 4' of freeboard. Ms. Jolly stated
that conditions had been dry, so pump -and -haul operations had not been necessary during the past few weeks.
7. Ms. Johnson pointed out the new flare that had been installed as a part of the landfill gas system. She explained
that the old flare was still in service, pending the switch -over that would be handled by Duke Power. She further
stated that discussions with Duke Power were still underway concerning the number and placement of new
power poles required for the landfill expansion.
8. The temporary leachate holding tank, located in the vicinity of MW-19, was inspected, and repairs and
maintenance to the tank and the corrugated plastic pipe feeding it were noted. The grade between the pipe and
the tank had been modified so that the pipe now feeds downhill and directly into the tank. Ms. Jolly stated that,
due also to dry weather, the tank had not been accumulating leachate, so emptying it had not been necessary in
recent weeks. The intent is to abandon the tank once the leachate collection system upgrades are completed as
part of the construction activities associated with the Phase 4 expansion.
9. New construction, taking place to the southeast of the active landfill, was observed, including the new landfill
cell, the new stormwater pond #4, and the new borrow area. Mr. Maimoun explained that bedrock had been
encountered during excavation for the pond, so blasting had been necessary. The drainage system leading to the
pond had been roughed in. Mr. Watkins commented that it appeared that a percentage of the surface water
flowing to the pond may inadvertently make it around the pond to the south without being captured by any
erosion control devices. It is recommended that temporary erosion control in the vicinity of Pond #4 be
investigated and, if needed, amended to contain waterflow coming from the new borrow area that could
circumvent the pond.
10. The new borrow area was in use at the time of this inspection. Trucks were observed loading soil for use in the
operations area of the active landfill.
11. A stockpile of land clearing debris, accumulated during construction, had been staged behind the borrow area.
12. The new landfill cell was also under construction. Mr. Maimoun stated that the second clay lift was in the
process of being installed. He added that construction is on schedule at this time.
13. The approach to the working face was dry and in good condition. The working face itself was small and
appeared to be well compacted.
14. The operations area surrounding the working face appeared to have light soil cover, allowing waste to become
uncovered and making it susceptible to becoming windblown. Consider applying additional cover in the
operations area to help prevent windblown litter.
15. The tipping area was tight due to the size and location of the remaining airspace in the active landfill. Traffic
flow appeared to be haphazard, and vehicles leaving the tipping area were observed choosing their own exit
strategies. In this situation where space is minimal, additional traffic control methods are recommended.
A spotter would be ideal. In the absence of a spotter, other means of defining the desired traffic flow and
restricting access to undesirable areas would allow vehicles and equipment to maneuver more safely in the
tipping area. Ms. Jolly pointed out that the landfill is short-staffed at this time, which would preclude a spotter.
16. Facility staff were observed removing a scrap tire from the working face and setting it to the side so it could be
moved to the tire collection area. No other unacceptable materials were found in the working face.
17. It is recommended that landfill staff consult with and monitor the activities of construction crews to ensure they
do not create compliance concerns for landfill operations during construction. Specifically, the following
observations of uncovered waste were made and need corrective action:
• In the area of the side slope adjacent to and southwest of the working face, the liner material that was
being installed as a part of the closure process ended. An area beside the edge of the liner material,
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oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
estimated to be 20' x 30' in size, had been excavated to a depth of approximately 12 inches. Mr.
Maimoun stated that the excavation had been done by the contractor to regrade the slopes for installation
of the next roll of liner material. He explained that the contractor had run out of liner material, so work on
the slopes had been stopped pending the arrival of additional supplies.
A large pile of drainage pipe that had been removed from the side slopes during installation of the liner
material had accumulated on the northern end of the landfill top. Waste was observed to be mixed into the
pile of pipe.
18. The top of the landfill outside of the current operations area was also inspected. Small piles of "dirty dirt" (soil
mixed with waste, such as would be found when soil cover is peeled back from the previous day's working face)
were found in several areas on the top of the landfill. Ensure that these piles of waste -contaminated soil and
any other trash that accumulates on top of the landfill are returned to the working face or covered at the
end of every working day, as required by 15A NCAC 13B .1626(2)(a).
19. Trash and small erosion rills were visible in several areas of the upper side slope adjacent to the access road to the
working face. Because the rills were observed from the perimeter road, it could not be determined whether the
trash was the result of windblown material from the working face or waste that was being uncovered as a result of
erosion. In several locations along this slope, truck tire tracks were observed from top to bottom of the slope.
Once slopes have been regraded, allowing staff or anyone to drive across those slopes is only creating
unnecessary additional repairs, and could lead to accelerated erosion of these areas. Ensure that repairs are
made to the side slopes that eliminate the erosion rills and cover accordingly to address any exposed waste.
20. Facility access roadways are of all-weather construction and were found to be in good condition. Ms. Jolly
explained that truck traffic to the working face had been detoured around the construction areas.
Post -inspection Meeting:
21. Mr. Neugent joined the group for a post -inspection meeting in the landfill office. He stated that he had been
operating equipment on the working face but had wanted to be present to discuss the observations that had been
made during the field inspection.
22. Wood waste operations were discussed, and Ms. Jolly stated that much of the waste accumulated in the designated
stockpile area had been dropped off by NCDOT during Hurricane Michael clean-up. She added that the county
would be responsible for disposal and would include that material in the annual grinding contract. Regarding the
disposition of the land clearing debris that had been stockpiled behind the new borrow area, Mr. Neugent stated
that it too would be included in the annual grinding contract for disposal. He confirmed that no burning would
take place.
23. Regarding soil sampling around the temporary leachate holding tank, Ms. Johnson stated that the testing report
had shown no impact from the collapse of the bank and that the report had been submitted to the Solid Waste
Section. Mr. Watkins stated that Ms. Heim would confirm receipt of the report following the inspection. Ms.
Heim followed up with Ms. Johnson via phone on 8/9 to request a copy of the report as it was not located in DEQ
records.
24. Regarding questions relating to the airspace information provided on the facility annual report, Mr. Maimoun
stated that he would review the figures and provide corrections via email following the inspection. At the time
this report was issued, no additional information relating to airspace used at the facility had been received
by the Solid Waste Section.
25. Mr. Watkins discussed the operations area surrounding the working face. He focused on traffic management,
stating that even though the tipping area is tight, trucks were maneuvering to various spots to exit and, as a result,
displacing existing cover and exposing waste. He recommended a spotter or other traffic control devices as a
possible solution that would help ensure safe maneuvering for equipment and vehicles.
26. Mr. Watkins also addressed uncovered waste, "dirty dirt" and trash mixed with construction supplies and debris
on top of the landfill. He recommended that facility staff closely monitor the activity of contractors so that all
waste is covered in a timely fashion, as required. He also emphasized that the facility ultimately bears the
responsibility for compliance with properly disposing and covering waste.
27. Mr. Watkins reiterated concerns about erosion control near Pond #4. He stated that the temporary erosion control
devices should be evaluated to ensure that all water will be contained, and no surface water flow could circumvent
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D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� Envimmenlal Oualiry
Solid Waste Section
the pond.
28. The Section greatly appreciates the recent efforts of the facility to address past violations and bring all items back
into compliance. As discussed, please continue to concentrate on staying in front of issues instead of working
from behind.
View of the leachate pond
Repairs were made to the temporary holding tank and the pipe that
carries leachate to it.
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oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
The operations area surrounding the working face is cleaner, with more soil cover to prevent exposing waste during
operations.
A view of the northwest slope of the active landfill where liner material has been installed as part of the closure
process.
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NORTH CAROLINAD_E Q��
Oeparfinenf of Envircnmenfal Onal�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A view of the active landfill (background) and new Phase 4 construction (foreground).
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan Heim
DN: cn=Susan Heim, o=Solid
Waste Section, ou=Field
Operations Branch,
email=[e-mail]
,c=US
Date: 2019.08.13 07:47:29
-04'00' Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: August 13, 2019 to
X
Email
Hand delivery
US Mail
Certified No. L_1
Lance Metzler and Ronnie
Tate.
Copies: Jason Watkins, Field Operations Branch Head — Solid Waste Section
Deb Aja, Western District Supervisor — Solid Waste Section
David Giachini, Permit Engineer — Solid Waste Section
Ervin Lane, Hydrogeologist — Solid Waste Section
Martie Neugent, Landfill Supervisor — Rockingham County
Kathryn Jolly, Environmental Compliance Solid Waste Program Manager — Rockingham County
Jenny Johnson — LaBella/Joyce Engineering
Mousa Maimoun — LaBella/Joyce Engineering
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