7904_INSP_20191022

oepamnem a� enmmnmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
X
LCID
YW
Transfer
Compost
SLAS
COUNTY: Rockingham
MSWLF
PERMIT NO.: 7904-MSWLF-1995
Closed
xxW
White
X
Incin
T&P
X
HRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
Tire T&P/
X
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: October 22, 2019
FACILITY NAME AND ADDRESS:
Rockingham County Landfill
281 Shuff Road
Madison, NC 27025
GPS COORDINATES: Lat: 36.36455 °
Date of Last Inspection: August 8, 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:
Edward Shelton, Landfill Supervisor — Rockingham County
Kathryn Jolly, Environmental Compliance Solid Waste Program Manager — Rockingham County
Ronnie Tate, Director of Engineering and Public Utilities — Rockingham County
Joe Ryder, Site Supervisor — LaBella Engineering
David Giachini, Permitting Engineer — Solid Waste Section
Ervin Lane, Compliance Hydrogeologist — 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 — LIFE OF SITE: Issued April 12, 2019
Permit to Construct Phase 4 Lateral Expansion: Issued April 12, 2019
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
N/A
Page 1 of 10

D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� Envimmenlal Oualiry
Solid Waste Section
OBSERVED VIOLATIONS:
A. CORRECTIVE MEASURES IN PROGRESS: 15 A NCAC 13B .1626(2)(a) states, in part: "the owners or
operators of all MSWLF units must cover disposed solid waste with six inches of earthen material at the end of
each operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing
litter, and scavenging."
Rockingham County is in violation of 15 A NCAC 13B .1626(2)(a) for failing to cover disposed solid waste
at the end of each operating day. Closure construction operations and rain had resulted in exposed waste on the
side slopes of the active landfill, and Mr. Shelton stated that no repairs had been undertaken to cover the exposed
waste in the areas where closure construction was taking place. However, facility staff were applying cover to
exposed waste on the interior slope adjacent to the working face during the inspection; and, Mr. Shelton provided
a photo following the inspection to verify that the pile of "dirty dirt" found at the edge of the new cell
construction had been disposed of in the working face.
To achieve compliance, Rockingham County must immediately cover all exposed waste, and take steps to
ensure that all waste is covered with at least 6" of clean soil or other approved alternative cover material at
the end of every operating day. Compliance inspections will be performed to ensure that cover is being
applied at least daily, as required by 15 A NCAC 13B .1626(2)(a).
Lef: A view from the top of the
landfill looking down the side slope
at uncovered waste.
Below: A view of uncovered waste
on the slope in the closure
construction area from the toe of
the slope.
Page 2 of 10

oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Exposed waste on an area of the slope
used by closure construction
contractors for access. Note
additional exposed waste to the left of
the access path nearer to the top of
the slope.
A view of a
slope where
closure
construction
is taking
place. Note
the waste
piles near the
landfill gas
line in the
foreground,
and the
exposed waste
evident near
the top of the
slope. Below
the area of
exposed
waste, a
trench for the
installation of
new landfill
gas line is
visible.
Page 3 of 10

oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Lei: Exposed waste near the top of the slope above
a trench to be used to install landfill gas line.
Below: Cover had been applied to exposed waste on
the same slope. (Photo provided by E. Shelton
10123119.)
Lg t: 'Dirty dirt" piled at the edge of the
new cell.
Below: "Dirty dirt" had been removed and
disposed of in the working face. (Photo
provided by E. Shelton 10123119.)
Page 4 of 10

oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A view of the interior slope adjacent
to the working face where facility
staff were observed applying cover to
exposed waste.
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:
1. The permit for this facility includes the following operations: active MSW landfill, scrap tire collection, white
goods collection and processing, compressed gas cylinder collection, electronics and TV collection, wood waste
collection and processing, inert debris collection and processing, and a convenience center for the drop-off of
residential wastes and single stream recyclable materials.
2. A landfill gas plant owned and operated by the county is located on the southeast side of the leachate pond. The
plant is not currently producing electricity, and all gas is routed to the flare.
3. The MSW landfill is currently operating in the Phase 3 vertical expansion. Construction of the new Phase 4 is
underway to the southeast of the current active landfill. It had originally been anticipated that waste would be
directed to the new phase sometime late in 2019 or early in 2020. However, Mr. Shelton stated that he now
estimates up to a year of capacity remains on the Phase 3 vertical expansion.
4. All photos included in this report were taken by Susan Heim during the inspection on October 22, 2019 unless
otherwise noted.
Field Inspection:
5. Signage was observed at the facility entrance listing the facility permit number, the hours of operation, and
unacceptable wastes. Ms. Jolly stated that she was preparing to order new signs for the facility entrance. Please
ensure that the signage at the facility entrance includes a contact name and telephone number, as
required by General Facility Operation Condition #10 of the Permit to Operate.
6. All of the following facility operations are located atop closed landfill units: white goods and scrap metal; wood
waste; scrap tires; inert debris; convenience center; residential recycling drop-off; electronics; and, container
storage.
7. The convenience area, recycling drop-off and electronics collection area were found to be clean and well -
maintained. The convenience area is manned during operating hours, and windblown litter is retrieved by
facility staff as it occurs.
Page 5 of 10

oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
8. Electronics and televisions are collected on a concrete pad located on the southwest side of the convenience
area. County staff sort, package and palletize materials for transport; and, full pallets are stored on a covered
pad next to the drop-off location. The electronics collection area was observed to be well organized. Only a few
televisions were found in the drop-off area, indicating that facility staff keep up with sorting and palletizing
materials as they are received.
9. Roll -off containers are staged along a gravel access road south of the convenience area. This area was observed
to be well -maintained, and the landfill cap appeared to be undamaged by the container operations. Scrap tire,
wood waste, inert debris, white goods/scrap metal operations and a maintenance building are located southeast
of the container storage area.
10. No tire trailers were present onsite during the inspection. A pile estimated to contain approximately 3,000 tires
was observed on the ground covering the concrete pad above the trailer parking bays and spilling onto the
gravel operating area surrounding it. The tire pile does not meet the parameters for the outside storage of scrap
tires, as set forth in 15A NCAC 13B .1107(2)(a), (b) and (c). The outside storage of scrap tires onsite had been
discussed during the previous inspection on August 8, 2019, when the stockpile size was estimated to be
approximately 1,500 tires. Ensure that scrap tires are removed from the facility within 10 days of receipt
or are stored and covered as stipulated in 15A NCAC 13B .1107(2)(a), (b) and (c).
11. Grinding operations were occurring in the wood waste collection area during the inspection. Piles of ground
wood waste and unprocessed material were separated by fire lanes that appeared to be adequately sized to
facilitate the use of emergency equipment, as required. No unacceptable waste was observed in the wood waste
collection area.
12. A large pile of cast iron pipe was stored in the area to the east of the wood waste operations on top of the closed
landfill cap. Mr. Shelton stated that a customer had brought several truckloads of the pipe to the landfill for
disposal, and that facility staff had separated it for recycling by the county's metal recycling contractor.
13. White goods and scrap metal are collected on a concrete pad located on the south side of the access roadway
next to the maintenance shed. Several units containing CFCs were staged in an upright position to prevent
leakage of refrigerant during storage. Roll -off containers are used for the collection of scrap metal and white
goods that do not contain refrigerant. At the time of this inspection, one roll -off container was being picked up
for transport to the county's scrap metal contractor for recycling. Please ensure that the stockpile of metal
pipe is removed by the county's metal contractor as soon as feasible; and, that any repairs to the landfill
cap that may be required as a result of the storing and removing of the pipe are performed promptly.
14. Partial closure had been approved by the Solid Waste Section for approximately 2/3 of Phases 1, 2 and 3 of the
active landfill. No work on the closure process was taking place during this inspection due to the periods of rain
that were occurring throughout the day.
15. Closure construction was found to have progressed since the previous inspection on August 8, 2019. The liner
material that had been installed on the slopes had since been covered with soil. Small erosion rills were visible
on these side slopes, and, in several spots, waste had been uncovered. Mr. Shelton stated that a rain event on
October 19t' coupled with the rain currently occurring was causing the damage. He also stated that no slope
repairs or covering of the exposed waste had been undertaken between the rain events. Sediment from the
closure cover soil had washed down the slopes into the perimeter ditch, filling it entirely in some places.
16. Trenches had been constructed on the slopes in the closure areas to accommodate the installation of slope drains
and new landfill gas lines. Excavation by the contractor had resulted in patches of uncovered trash throughout
these slopes, and the rain event on Saturday, coupled with the rain on the day of the inspection was eroding the
trenches and carrying the exposed waste. Mr. Shelton stated that he was hesitant to have facility staff apply soil
cover in areas where the contractor's construction crews had not completed their work. Ensure that all
disposed waste is covered with 6" of earthen material, or approved alternative cover material, at the end
of each operating day, as required by 15A NCAC 13B .1626(2)(a) and (b). (See Observed Violations
section of this report for additional information.)
17. Access roadways at the facility are of all-weather construction and generally in good condition. The perimeter
roadway around the active landfill is paved and well -maintained.
18. The access road to the working face was wet but stable, with no appreciable mud build-up, allowing for safe
navigation by trucks and heavy equipment using the roadway. Rainwater was observed to be flowing down the
roadside ditch, carrying some loose waste from the operations area with it. Large cracks and rills were visible
Page 6 of 10

D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� EnvimmenUl Oualiry
Solid Waste Section
on the slope on the south side of the road, and uncovered waste was observed to be prevalent in some areas. The
interior slope adjacent to the working face had been partially covered with clean soil, and Mr. Shelton stated
that this work would be completed during the day as weather conditions would permit.
19. The working face itself was observed to be small and appeared to be well compacted. Waste appeared to be
contained successfully within the working face, and windblown litter was well managed. No unacceptable waste
was observed in the working face during the inspection. A large tractor tire had been pulled from the working
face and set aside to be taken to the scrap tire collection area at the close of daily operations.
20. Improvements to operational procedures in and around the working face were noted, as was the positive impact
achieved as a result. The operations area surrounding the working face appeared to have adequate soil cover so
that trucks and equipment could maneuver without exposing waste. In addition, the tipping area was sized and
laid out so that ample space was provided for vehicles to unload, turn and arrive/depart the area safely.
Equipment operators were observed working to keep the tipping area dry and well covered.
21. Construction of Phase 4 was in progress southeast of the active landfill. Lines of dump trucks were observed
bringing rock that was being placed on top of the liner in the new cell. Rainwater had resulted in water ponding
in the bottom of the cell.
22. The leachate pond appeared to be in good condition with adequate freeboard. However, the level marker was
obscured by the rain, so it was not possible to determine the exact level of the pond during the inspection. Mr.
Shelton stated that conditions at the facility had been so dry that pumping and hauling operations had been
halted for several months.
23. The old flare that is part of the landfill gas system was still in service, pending the switch -over to the new flare
that would be accomplished by Duke Power.
24. Mr. Tate stated that the temporary leachate holding tank, located in the vicinity of MW-19, was still in place
and functioning properly. All of the leachate line had been installed that will connect Phase 4 to the lines of the
active landfill, thereby eliminating the need for the tank. He explained that a decision had been made to install a
pump system that would transmit the leachate to the storage pond instead of designing and installing a gravity
conveyance system. Mr. Shelton stated that he was unsure as to exactly how much of the leachate collection
system for Phase 4 had been completed, but that he believed construction was on schedule.
25. During the previous inspection on August 8, 2019, it had been recommended by the Solid Waste Section that
some form of temporary erosion control be explored for use in the vicinity of Pond #4 to ensure that waterflow
coming from the borrow area could not circumvent the pond. Mr. Shelton stated that these issues had been
resolved, and that all water that was being directed to Pond #4 was now being captured there.
26. The borrow area is located southeast of the Phase 4 and was in use at the time of this inspection. Trucks were
observed carrying soil to the operations area of the active landfill for use as cover.
27. A stockpile of rock that had accumulated as a result of blasting during the construction of Pond #4 had been
stockpiled between the borrow area and the new cell. Mr. Giachini asked if the land clearing debris that had
been staged behind the borrow area had been removed for grinding and disposal by the county's contractor, and
Mr. Tate stated that it had not yet been removed. During the previous inspection on August 8, 2019, Mr.
Neugent had stated that this wood debris would be included in the county's annual grinding contract, and that
no burning would take place. Grinding operations are now in progress at the facility, and it is presumed that this
material will be removed as part of those grinding operations.
28. Small piles of "dirty dirt" (soil mixed with waste), along with a large pile of drainage pipe that had been
excavated during closure construction activities, had been found in several areas on the top of the landfill during
the previous inspection on August 8, 2019. Mr. Shelton stated that all of these materials had been disposed of in
the working face as required.
29. One pile of soil mixed with waste had been deposited near the rim of the new cell. Mr. Shelton stated that he
would have the pile moved to the working face by the end of the day's operations.
30. Edge of waste markers at the active landfill were not in place due to Phase 4 construction activities. Mr. Shelton
stated that they would be re -installed as construction activities were moved away from the boundary of Phase 3.
Records Inspection and Review:
31. Mr. Tate was obliged to leave following the field inspection, prior to the review of facility records.
Page 7 of 10

D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� EnvimmenUl Oualiry
Solid Waste Section
32. The report covering soil sampling around the temporary leachate holding tank was submitted to the Solid Waste
Section for review following the previous inspection on August 8, 2019, as requested. Mr. Lane had confirmed
that no contamination had been documented in the report.
33. As requested during the previous inspection on August 8, 2019, Moussa Maimon, LaBella Engineering, provided
information relating to the airspace data included on the facility annual report following the previous inspection
on August 8, 2019. As a result, the report was revised by the Solid Waste Section to include the corrected data,
with the approval of Ms. Jolly.
34. The current Permit to Operate, dated April 12, 2019 and issued for the life of the site, was available at the landfill
office and was reviewed with Mr. Shelton and Ms. Jolly. The latest approved Operations Plan, revised March
2019, was not available onsite as required. However, a copy was provided by the Solid Waste Section that was
also reviewed with Mr. Shelton and Ms. Jolly. Please ensure that a copy of the current Operations Plan is
maintained at the landfill office and is available for review upon request as required by the Permit to
Operate.
35. A notebook containing monthly reports of facility tonnage and other activities had been assembled, and Ms. Jolly
stated that it is maintained in the landfill office. A review of this record, which appeared to contain data for at
least the 3 most recent years of operations, yielded the following information:
• MSW accepted at the landfill during the current fiscal year (July 1 — September 30, 2019) totaled
26,471.64 tons;
• No leachate was pumped from the storage pond and hauled for disposal during the current fiscal year;
• Records of monthly flare inspections ended with 6/30/19; (Mr. Shelton explained that inspections were
discontinued when a large portion of the landfill gas system had been disassembled during Phase 4
construction.)
• A total of 99 white goods units containing refrigerants were accepted during the current fiscal year; (Mr.
Shelton confirmed that Rapid Recovery is still the county's contractor for CFC removal.)
• 62.96 tons of scrap metal (including non-CFC white goods units) had been recovered at the facility during
the current fiscal year; (Mr. Shelton stated that Foss Recycling continues to be the county's scrap metal
recycling contractor.)
• 422.59 tons of scrap tires had been collected and removed from the facility during the current fiscal year;
(Ms. Jolly stated that New River Tire remains the county's scrap tire disposal contractor.)
• 15.00 tons of electronics and televisions were collected and removed from the facility during the current
fiscal year; (Mr. Shelton confirmed that Synergy Electronics Recycling is still the county's electronics
recycling contractor.)
• The latest inspection of the back-up generator was performed by Nixon Power Services on 7/1/19;
• The last report of landfill gas system tuning was dated February 2019; (Mr. Shelton stated that tuning had
been stopped due to Phase 4 construction that dismantled much of the landfill gas system.)
• The facility operates under an NC General Storm Water Permit and DEMLR-approved erosion control
plans, all of which were available for review.
36. Random waste screening is conducted at least once a day (6 per week), as had been discussed and agreed upon
during the previous comprehensive inspection on October 30, 2018. This rate allows the facility to comply with
the inspection rate of 1 % of incoming waste by load that is specified in the Operations Plan. Mr. Shelton stated
that additional screenings are done if questionable loads are identified by the scale house operator. The completed
waste screening forms are kept in a notebook at the landfill office. A review of these records found the forms to
be filled out correctly, including the disposition of any wastes that were separated for disposal elsewhere at the
facility or that were returned with the customer.
37. Scrap tire certifications for the current month are kept in the scale house. Older certification forms are stored in
the governmental center. The certification forms for October were reviewed. It was noted that on many of the
forms, no dates for the accumulation of scrap tires was noted. Requiring scrap tire generators to provide the dates
during which scrap tires are accumulated provides the county with a means of comparing the number of tires
received at the landfill to sales receipts recorded at the generator's place of business, and thereby determining how
many scrap tires the generator is eligible to dispose of at no charge. Please ensure that all information required
on scrap tire certification forms is provided by the scrap tire generator prior to accepting the tires for
disposal.
Page 8 of 10

D_E FACILITY COMPLIANCE INSPECTION REPORT
NOFTH CAaOLiNA Q�� Division of Waste Management
U.paN td—im-1 Quality
Solid Waste Section
38. Some discussion followed concerning the county's scrap tire program. Ms. Jolly asked how the county could put
together an enforcement program that would address scrap tires coming in to the facility that may not be eligible
for free disposal. Several enforcement options were briefly discussed. Please contact John Patrone,
Environmental Senior Specialist — Solid Waste Section — at 336-776-9673 or via email at
[e-mail] for additional assistance.
39. Information was requested about the county's scrap tire disposal contract and provisions for tire trailers to be
maintained at the collection area. Ms. Jolly stated that the county had not been receiving tire trailers on a regular
basis for a number of months. Mr. Shelton estimated that only one or two trailers were brought in per week by
New River Tire, the county's current disposal contractor. No tire trailers were present at the collection area during
this inspection, and it is estimated that at least 3,000 tires are piled up on the ground now — a volume that would
require at least three trailers to contain and remove.
• Information was provided verbally to Ms. Jolly and Mr. Shelton about the requirements for the
outside storage of scrap tires, as set forth in 15A NCAC 13B .1107(2)(a), (b) and (c), during the
inspection and a copy of the rule is included as an attachment to the email that contains the link to
this inspection report.
• It is recommended that Mr. Tate, Ms. Jolly and Ms. Heim discuss the county's plans for managing
scrap tire collection and storage at the facility via a conference call. Please let me know when such a
call would be convenient.
40. Records for the required groundwater and landfill gas monitoring were not available at the landfill office for
review and verification. However, Mr. Lane stated that he believed monitoring reports had been submitted that
indicate the county is following the required sampling schedule and frequency. A review of the monitoring reports
found in Laserfiche following the inspection confirmed Mr. Lane's belief. Please ensure that digital copies of
groundwater and landfill gas monitoring records and reports are available for review at the landfill office.
41. Training records for certified staff were not up to date. However, Mr. Shelton provided copies of current
certificates for the following facility staff members via email following the inspection:
• Edward Shelton — NC Certified Landfill Manager —expires 12/4/2021;
• Facio I. Visaya — SWANA Certified Manager of Landfill Operations —expires 6/14/2021;
• Jeff Ikerd — NC Certified Landfill Operator — attended 9/11/19 Joyce Engineering class in High Point -
certificate not yet received.
Ms. Jolly stated during the inspection that she and Mr. Tate had not received their SWANA MOLO renewal
certificates due to an issue with records. She added that there may also be other staff members that hold current
certifications, and that she would have to find and forward them following the inspection. Information about
upcoming certification classes was emails to Mr. Shelton following the inspection, as he requested. Please note
that a responsible individual certified in landfill operations must be present at the landfill during all
operating hours, as required by General Facility Operation Condition #8(a) of the Permit to Operate.
42. Information concerning the cleaning and televising of the facility's leachate collection lines was requested, and
Ms. Jolly stated that, to her knowledge, no such activity had taken place since during her four-year tenure.
General Facility Operation Condition #18 of the Permit to Operate states, in part, "Remote camera
inspections of leachate lines must be conducted at least once every five years," and that, "cleaning of
leachate collection lines must be conducted as necessary for proper functioning and to address buildup of
leachate on the liner." Please provide records for the most recent remote camera inspection and cleaning of
facility leachate lines.
Page 9 of 10

oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Above: A view from the access road of the scrap tires piled in the collection area.
Below: A view of the tire collection area from the maintenance building. Note the empty trailer docks at left.
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,h,Field
Operations Branch,
email=[e-mail]
v, c=US
Date: 2019.10.25 11:15:11
-04'00'
Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: October 25, 2019 to
X
Email
Hand delivery
US Mail
Certified No.
Ronnie Tate via:
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
Kathryn Jolly, Environmental Compliance Solid Waste Program Manager — Rockingham County
Edward Shelton, Landfill Supervisor — Rockingham County
Page 10 of 10