4117_NOD_20210107

North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8200

January 26, 2021

CERTIFIED MAIL 7017-1450-0001-6450-6865
RETURN RECEIPT REQUESTED
A-1 Sandrock, Inc.
Attn: Ronnie Petty, Owner 2111 Bishop Road Greensboro, NC 27406
SUBJECT: Notice of Deficiency
Compliance Inspection Report
A-1 Sandrock, Inc. C&D Landfill
41-17
Guilford County

Dear Mr. Petty:

On January 7, 2021, Chuck Kirchner, representing the State of North Carolina, Division of Waste
Management Solid Waste Section (Section), inspected the above referenced facility for
compliance with North Carolina solid waste statutes and rules. Jason Tarkenton, General
Manager was present and represented A-1 Sandrock, Inc. C&D Landfill during this inspection.
The following violations were noted:

A. 15A NCAC 02L .0110(c) – “Monitoring shall be conducted and results reported in a
manner and at a frequency specified by the Director, or his designee.”

B. 15A NCAC 13B .0203(d) – “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.”

General Facility Permit Condition, Attachment I, Part I, Number 5 states: “By receiving
waste at the facility, the permittee shall be considered to have accepted the terms and
conditions of this permit in accordance with Rule 15A NCAC 13B .0203(d).”

North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8200
A-1 Sandrock, Inc. C&D Landfill
Notice of Deficiency
Page 2 of 3
January 26, 2021

General Facility Permit Condition, Attachment III, Part I, Number 16 states in part:
“surface water locations, and groundwater monitoring wells must be sampled at least
semi-annually in accordance with Rule 15A NCAC 13B .0544(b)(l)(D), the approved
monitoring plan (FID 1285092).”
Groundwater Sampling and Analysis - Approved Monitoring Plan (FID 1285092), dated
December 20, 2018, Section 2.1 (Included as Appendix 5 in the Operations Plan dated
January 15, 2019) states: “Sampling shall be conducted on a semi-annual basis,
specifically once in the spring and once in the fall. Monitoring shall be conducted for the
duration of operations and for a minimum of 30 years following final closure.”

C. 15A NCAC 13B .0544(b)(1)(D) – “The monitoring frequency for all detection monitoring
constituents must be at least semiannual during the active life of the facility, and during the
closure and post-closure periods.”

A-1 Sandrock, Inc. failed to conduct the spring semiannual groundwater and surface water
sampling event in 2020 as required by 15A NCAC 2L .0110(c), 15A NCAC 13B .0203(d) and 5A
NCAC 13B .0544(b)(1)(D).

The above violations may have or can compromise the facility’s ability to ensure protection of
the public health and the environment and thus require remedial action on behalf of the facility
in order to maintain compliance with 15A NCAC 2L .0110(c), 15A NCAC 13B .0203(d) and 15A
NCAC 13B .0544(b)(1)(D). In order to resolve these issues, A-1 Sandrock, Inc. C&D Landfill must
take the following actions:

1. Conduct semi-annual groundwater sampling and surface water sampling as required by
the monitoring plan approved by the Division.

The violations 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.

North Carolina Department of Environmental Quality | Division of Waste Management 217 West Jones Street | 1646 Mail Service Center | Raleigh, North Carolina 27699-1646 919.707.8200
A-1 Sandrock, Inc. C&D Landfill
Notice of Deficiency
Page 3 of 3
January 26, 2021

Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct
a follow-up inspection to verify that the facility has completed the requirements of this Notice of
Deficiency.

If you have any questions please contact me at [phone] or e-mail
[e-mail].

Sincerely,

Chuck Kirchner
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section

copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section
Deb Aja, Western District Supervisor – Solid Waste Section
Jessica Monte, Compliance Officer – Solid Waste Section
Christine Ritter, Hydrogeologist – Solid Waste Section
Jason Tarkenton, General Manager – A-l Sandrock, Inc.,
[e-mail]