9704_INSP_20230216

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 7

UNIT TYPE:
Lined
MSWLF X LCID YW X Transfer Compost X SLAS COUNTY: Wilkes
Closed
MSWLF HHW White
goods X Incin T&P X FIRM PERMIT NO.: 9704-MSWLF-1993
CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: February 16, 2023 Date of Last Inspection: September 9, 2022

FACILITY NAME AND ADDRESS:
Wilkes County Roaring River Landfill
9219 Elkin Highway
Roaring River, North Carolina 28669

GPS COORDINATES (decimal degrees): Lat.: 36.21092 Long.: -80.98776

FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Anderia Byrd, Solid Waste Director
Telephone: [phone] (o) or [phone] (m)
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
Post Office Box 389
Roaring River, North Carolina 28669

PARTICIPANTS:
Anderia Byrd, Solid Waste Director – Wilkes County
Jason Wolfe, Landfill Supervisor – Wilkes County
Charles Gerstell, NCDEQ – Solid Waste Section

STATUS OF PERMIT:
A Permit Approval to Operate MSW Landfill Phases 1 – 5 was issued to Wilkes County on October 6, 2022.

PURPOSE OF SITE VISIT:
Partial Inspection

STATUS OF PAST NOTED VIOLATIONS:
N/A

OBSERVED VIOLATIONS:

A. 15A North Carolina Administrative Code 13B .1626(2)(b) states: “Except as provided in Sub-Item (c) of this
Item, the owners or operators of all MSWLF units shall 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 prevent the escape of waste
and the attraction of vectors and scavenging, and to minimize fires and the generation of odors.”

During the inspection, an area of exposed waste, approximately 50-feet x 50-feet was observed south of the working
face near the transition point between Phase 3 and Phase 5. According to facility staff, this area had not been
covered with soil in approximately 3-weeks. Therefore, Wilkes County is in violation of 15A NCAC 13B
.1626(2)(b) for failure to cover waste with six inches of earthen material at the end of the operating day as required.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 7

`To achieve compliance, within 5-days of receipt of the Notice of Violation, all exposed waste within the
landfill must be covered with a minimum of 6-inches of earthen material or approved alternative material.

2/16/23: View of exposed waste in Phase 5
(photo by C. Gerstell)

B. 15A North Carolina Administrative Code 13B .1626(7) states: “Erosion and sedimentation control requirements.
Erosion control measures consisting of vegetative cover, materials, structures, or other devices shall be utilized to
prevent silt from leaving the site and to prevent on-site erosion, and shall comply with 15A NCAC 04, which is
incorporated by reference including subsequent amendments and editions.”

During the inspection, severe erosion resulting in exposure of waste was observed on the western inactive slope of
Phase 5 of the landfill adjacent to the access road. Wilkes County is in violation of 15A NCAC 13B .1626(7) for
failure to prevent erosion as required.

2/16/23: View of eroded gully near 2/16/23: Additional view of eroded
top of inactive west slope of Phase 5 gully on inactive west slope of Phase 5
(photo by C. Gerstell) with exposed waste (photo by C. Gerstell)

To achieve compliance, within 5-days of receipt of the Notice of Violation, all areas of slope erosion must be
repaired to proper design.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 7

C. 15A North Carolina Administrative Code 13B .1626(11) states: “Windblown waste requirements. Methods such
as fencing and diking shall be provided within the area to confine solid waste that is subject to be blown by the wind.
At the conclusion of each operating day, all windblown material resulting from the operation shall be collected and
disposed of by the owner or operator.”

During the inspection, windblown waste was observed at the southeast corner of Phase 5 at the transition point to
Phase 3. Waste was imbedded in tall grass indicating it had been deposited for quite some time and had not been
collected at the conclusion of the previous working day. Therefore, Wilkes County is in violation of 15A NCAC
13B .1626(11).

2/16/23: View of windblown waste at southeast
corner of Phase 5. (photo by C. Gerstell)

To achieve compliance, within 5-days of receipt of the Notice of Violation, all windblown waste must be
collected and properly disposed.

D. 15A North Carolina Administrative Code 13B .1626(8)(d) states: “Leachate shall be contained within a lined
disposal cell or leachate collection and storage system. All leachate shall be treated, as required by the receiving
facility, prior to discharge. A National Pollutant Discharge Elimination System (NPDES) permit may be required
prior to the discharge of leachate to surface waters, as provided by 40 CFR 258.26 and 258.27.”

During the inspection, multiple leachate outbreaks were observed on the western, inactive slope of Phase 5 adjacent
to the access road. Leachate was observed flowing from two of the outbreaks beyond the edge-of-waste markers and
into the roadside ditch on the west side of the landfill. Ms. Byrd confirmed the liner system did not extend under the
roadside ditch. Leachate was then observed entering a concrete culvert which leads to the storm water system that
conveys storm water into a sediment basin. Wilkes County is in violation of 15A NCAC 13B .1626(8)(d) for failure
to contain leachate within the lined disposal cell or leachate collection system or treat the leachate prior to discharge.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 7

2/16/23: View of leachate leading from 2/16/23: View of leachate flowing north
eroded gully along catch fence adjacent along catch fence. (photo by C. Gerstell)
to access road. (photo by C. Gerstell)

2/16/23: View of leachate at point where 2/16/23: View of leachate flowing into
flows into roadside ditch beyond the roadside ditch. (photo by C. Gerstell
liner (photo by C. Gerstell)

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 7

2/16/23: View of additional leachate 2/16/23: View of leachate flowing along
Outbreak with gas boiling from slope roadside ditch on west side of Phase 5.
(photo by C. Gerstell) (photo by C. Gerstell)

2/16/23: View of leachate flowing into
Culvert which leads to sediment basin on
Opposite side of access road (photo by
C. Gerstell)

To achieve compliance, within 5-days of receipt of the Notice of Violation, Wilkes County must make all
necessary repairs to the western slope at the leachate outbreak locations.

Contact Mr. Ervin Lane, Compliance Hydrogeologist, to determine the requirements for a soil sampling plan
to determine the impact of the leachate release. Pending the laboratory analytical results, additional measures
may be required.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 7

ADDITIONAL COMMENTS

1. This was a partial inspection to observe the operations of the facility.
2. The facility has a service area of Wilkes County only.
3. A gate was located at the entrance to the facility to prevent unauthorized access when not open to the public.

Operations Inspection of the MSWLF Unit:

4. Waste was being placed on the north side of Phase 5 at the time of inspection.
5. The working face was of manageable size at the time of inspection.
6. During the inspection, a tire was off-loaded at the working face. Facility staff immediate took steps to remove the
tire for proper disposal. Thank you for your efforts to monitor and address unacceptable waste streams as they are
observed.
7. During the inspection, standing water was observed in multiple vehicle ruts on the south side of Phase 5 as the
result of recent rains. Please ensure these areas are regarded to prevent future standing water.
8. Edge-of-waste markers were in place around the perimeter of the landfill.
9. Access roads were of all-weather construction and well maintained.
10. During the inspection, significant dust was observed from vehicle traffic on the primary access road surrounding
the landfill. Please ensure steps are taken to control excess dust such as utilization of the water truck.

Operations Inspection of the Treatment and Processing Area:

11. Land clearing waste and wooden pallets were being placed into separate stockpiles separated by earthen berms.
12. Grinding of land clearing debris is contracted to a third party. Ground material is used within the facility and is not
distributed to the public.
13. Although the facility is permitted to operate a Type 1 compost unit, no compost activities currently take place on
site. Yard trash is not accepted at the facility.
14. A small amount of standing water was observed in ruts left by vehicle traffic. Please ensure areas of standing
water are graded to prevent this condition.
15. No objectionable odors were observed.
16. No unacceptable waste streams were observed.

Operations Inspection of the White Goods Area:

17. All white goods containing CFCs are staged adjacent to the public convenience area prior to removal of
chlorofluorocarbons (CFCs). Once CFCs are removed, appliance are placed at the metal area to be loaded onto the
designated trailer.
18. This area was well managed.

Operations Inspection of the Tire Collection Area:

19. Tires were being collected into one of three covered trailers located southwest of the public convenience area.
20. All tires were maintained to the designated trailers at the time of inspection.
21. This area was well managed.

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 7

Supporting Comments:

22. The facility operates a convenience area for the collection of mixed paper, plastic and glass bottles, cardboard,
steel and aluminum cans, batteries, used oil filters, and antifreeze. Roll-off containers are also provided for
disposal of municipal solid waste to prevent the general public from having to enter the active landfill area.
• Facility staff were picking up windblown waste adjacent to the convenience area at the time of inspection.
• Please ensure all waste deposited on the ground at the roll-off containers collected and properly disposed at
the end of the working day.
23. Electronics are collected on a covered concrete pad adjacent to the tire collection trailers and then placed on
pallets, shrink wrapped, and finally placed into a covered trailer for shipment off site. This area was well
managed.

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

________________________________________ Phone: [phone]
Charles T. Gerstell
Environmental Senior Specialist
Regional Representative

Sent on: 2/23/23 X Email Hand delivery X US Mail
(w/ NOV) Certified No. [ _]

Electronic Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section
Deb Aja, Western District Supervisor – Solid Waste Section
Chris Hollinger, Compliance Officer – Solid Waste Section
Anderia Byrd, Solid Waste Director – Wilkes County