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HomeMy WebLinkAbout7904_INSP_20161213FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 13 UNIT TYPE: Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: Rockingham Closed MSWLF HHW White goods X Incin T&P X FIRM PERMIT NO.: 7904-MSWLF-1995 CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: 12/13/2016 and 12/16/2016 Date of Last Inspection: 05/07/2015 FACILITY NAME AND ADDRESS: Rockingham County Landfill 281 Shuff Road Madison, NC 27025 GPS COORDINATES: N: 36.36455° W: - 79.84336° FACILITY CONTACT NAME AND PHONE NUMBER: Name: Kathryn Jolly, Environmental Compliance Solid Waste Program Manager Telephone: 336-941-7175 Email address: kjolly@co.rockingham.nc.us FACILITY CONTACT ADDRESS: P. O. Box 132 Wentworth, NC 27375 PARTICIPANTS: Martie Neugent, Landfill Supervisor – Rockingham County (12/13/16 and 12/16/16) Kathryn Jolly, Environmental Compliance Solid Waste Program Manager – Rockingham County (12/16/16 only) Deb Aja, Western District Supervisor -- Solid Waste Section (12/13/16 only) Kim Sue, Environmental Senior Specialist – Solid Waste Section (12/13/16 only) Susan Heim, Environmental Senior Specialist, Solid Waste Section (12/13/16 and 12/16/16) 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 Phase 3 Vertical Expansion: Issued August 27, 2013 Permit Expires February 27, 2018 PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 13 OBSERVED VIOLATIONS: 1. 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. 7904-MSWLF-1995, ATTACHMENT 1, PART IV, General Permit Condition #6 states, “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, the conditions contained in this permit, and the approved plan.” Permit to Operate No. 7904-MSWLF-1995, PART IV, General Permit Condition #7 states, “This permit is issued based on the documents submitted in support of the application for permitting the facility including those identified in ATTACHMENT 3, “List of Documents for Approved Plan,” and which constitute the approved plan for the facility.” Permit to Operate No. 7904-MSWLF-1995, ATTACHMENT 1, Part II, Item 9 lists MSW Permit Amendment & Vertical Expansion as one of the documents for the Approved Plan. Item 3.2, Random Selection, of Section V – Operations Plan (Revised August 2012), MSW Permit Amendment & Vertical Expansion states, “While all incoming loads of waste are visually observed as they enter the facility, loads will be randomly selected on a regular basis for a thorough inspection of their contents. The personnel conducting the inspection will randomly select at least one vehicle per week at the working face. At least 1% of the waste stream by weight will be inspected in this manner.” Item 3.3, Record Keeping, of Section V – Operations Plan (Revised August 2012) states, “Sample report forms for record-keeping purposes are included in Appendix IV-1. These forms are completed at each inspection. Beginning in 2005, all reports and resulting correspondence are maintained at the Rockingham County Landfill office for a minimum of five years.” Rockingham County is in violation of 15A NCAC 13B .0203(d) as a result of failing to perform and/or document the required waste screening provisions stated in Section V- Operations Plan (revised August 2012). An inspection of the waste screening records for the active MSW landfill from January 1, 2016 through December 13, 2016 revealed deficiencies in the number of waste screenings performed and/or documented. Records for the following months indicated fewer screenings than required: January 2016, February 2016, March 2016, April 2016, June 2016, July 2016, August 2016, October 2016, November 2016 and December 2016. To achieve compliance, Rockingham County must immediately begin to perform and document the required number of random waste screenings and maintain the required records of same. 2. 15A NCAC 13B .1626(2)(a) states: “The owners and 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 15A NCAC 13B .1626(2)(a) by failing to completely cover all disposed solid waste with six inches of earthen material or the facility’s approved alternative daily cover (tarps) at the end of each operating day. The facility is permitted to use tarps as alternative daily cover, with soil coverage weekly. The facility maintains four 50’ x 100’ tarps that are deployed using a tarp-o-matic. Upon initial inspection on 12/13/2016, the working face of the landfill was very large and was observed to have inadequate cover, thus allowing waste to remain exposed and to become windblown. Mr. Neugent explained that as the size of the working face expanded in recent weeks, the tarps were not sufficient to cover all of the waste. In addition, during the completion of the inspection on 12/16/16, Mr. Neugent stated that the working face of the landfill had not been adequately covered for a month or more. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 13 During the completion of the inspection on 12/16/2016, observation of the working face revealed progress had been made in reducing the size of the working face and in beginning the placement of daily cover in the area of the working face. However, large areas of the side slopes are also lacking adequate cover. To achieve compliance, Rockingham County must immediately apply cover to all areas where waste is exposed to achieve the required 6-inch layer of soil. 3. 15A NCAC 13B .1626(11)(a) states: “MSWLF units shall restrict solid waste into the smallest area feasible.” Rockingham County is in violation of 15A NCAC 13B .1626(11)(a) by failing to restrict solid waste into the smallest area feasible. Upon initial inspection on 12/13/2016, the working face of the active MSW landfill was observed to be very large. During the completion of the inspection on 12/16/16, facility staff stated that the working face had not been completely covered in more than a month. To achieve compliance, Rockingham County must restrict solid waste into the smallest area feasible, and establish a working face that can be maintained and adequately covered at the end of each working day. Above: Area surrounding working face. Inadequate cover and windblown litter. Above: Working face. Note small soil piles forming a berm at toe of working face. Below: Access road just below working face. Uncovered and windblown waste. Below: View of the entire length of the working face. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 13 4. 15A NCAC 13B .1626(7)(a) states: “Adequate sediment control measures shall be utilized to prevent silt from leaving the MSWLF facility.” Rockingham County is in violation of 15A NCAC 13B .1626(7)(a) by failing to prevent silt from leaving the MSWLF facility. Upon initial inspection on 12/13/2016, most of the western slope of the active landfill showed evidence of severe erosion, where silt containing exposed waste had flowed to the toe of the landfill and into the storm water inlets. In one area, a berm had been constructed on the access roadway to prevent additional silt from crossing the road and continuing downhill into the grassy areas west of the roadway and also into the leachate pond. Many other areas of erosion along the slopes of the active landfill were also observed. To achieve compliance, Rockingham County must ensure that erosion control measures are sufficient to prevent silt from leaving the MSWLF facility and to prevent on-site erosion. 5. 15A NCAC 13B .1626(7)(b) states: “Adequate sediment control measures shall be utilized to prevent on-site erosion.” Rockingham County is in violation of 15A NCAC 13B .1626(7)(b) by failing to prevent on-site erosion. Upon initial inspection on 12/13/2016, most areas of the side slopes of the active landfill showed evidence of severe erosion, which had resulted in the development of deep ruts and gullies where waste had been pulled downhill with the cover dirt and sediment, and had been left exposed in the rills. Little or no vegetative cover was in evidence that would assist in controlling the erosion. To achieve compliance, Rockingham County must ensure that erosion control measures are sufficient to prevent on-site erosion. All slopes must be inspected regularly to spot and repair erosion when it starts, and to ensure that vegetative cover becomes well established. Erosion of side slopes with silt and sediment running into storm water collection ditch. Left: Silt overtaking access roadway guard rail. Right: Sediment filling storm water collection ditch and inlets. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 13 6. 15A NCAC 13B .1626(7)(c) states: “Provisions for a vegetative ground cover sufficient to restrain erosion must be accomplished within 30 working days or 120 calendar days upon completion of any phase of MSWLF development.” Rockingham County is in violation of 15A NCAC 13B .1626(7)(c) by failing to provide for a vegetative cover sufficient to restrain erosion within 30 working days or 120 calendar days of completion of any phase of MSWLF development. Upon initial inspection on 12/13/2016, most areas of the side slopes of the active landfill showed evidence of severe erosion and were observed to have little or no vegetative cover established that would prevent erosion. To achieve compliance, Rockingham County must ensure that sufficient vegetative cover is established on the landfill slopes to prevent erosion. Vegetation must be well established to demonstrate compliance. 7. 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. 7904-MSWLF-1995, ATTACHMENT 1, PART IV, General Permit Condition #6 states, “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, the conditions contained in this permit, and the approved plan.” Permit to Operate No. 7904-MSWLF-1995, PART IV, General Permit Condition #7 states, “This permit is issued based on the documents submitted in support of the application for permitting the facility including those identified in ATTACHMENT 3, “List of Documents for Approved Plan,” and which constitute the approved plan for the facility.” Permit to Operate No. 7904-MSWLF- 1995, ATTACHMENT 1, Part II, Item 9 lists MSW Permit Amendment & Vertical Expansion as one of the documents for the Approved Plan. Item 2.5, Special Wastes, of Section V – Operations Plan (Revised August 2012), MSW Permit Amendment & Vertical Expansion states, “Clean wood wastes are accepted at this facility, but are not disposed of in the landfill. This waste stream is processed in the composting area, where it is chipped, shredded, and placed in windrows for mulching. The final product is sold to the public or private industries/businesses as boiler fuel.” Rockingham County is in violation of 15A NCAC 13B .0203(d) by making the processed wood waste available to the public as a product other than boiler fuel. During the inspection, Mr. Nuegent stated that the processed wood waste is being sold to the public as mulch. Deep ruts and rills on side slopes caused by erosion. Left: Edge of waste markers in foreground. Vegetative cover washed away except in areas beyond liner. Right: Soil berm created at edge of access road to block soil and waste from entering roadway. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 13 To achieve compliance, Rockingham County must take one of the following courses of action: 1) cease selling processed wood waste to the public as mulch; or, 2) amend the approved Operations Plan to permit processed material to be sold to the public as mulch. During the completion of the inspection on December 16, 2016, Ms. Jolly notified county staff that mulch would no longer be offered for sale to the public; she also removed information about the sale of mulch from the county’s website. 8. 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. 7904-MSWLF-1995, ATTACHMENT 3, PART V, Miscellaneous Treatment and Processing Unit Specific Condition #29 states, “Wastes received and product stored shall be maintained in reasonably sized piles with adequate fire breaks and lanes in accordance with the approved operational plans and the pertinent rules.” Rockingham County is in violation of 15A NCAC 13B .0203(d) by storing wood wastes received in a single large pile with insufficient fire breaks and lanes. During the inspection, the wood waste pile appeared to be approximately 200’ long, 25’ tall, and varying in width from approximately 20’ to 60’. Mr. Nuegent stated that the pile is allowed to accumulate for a two-year period before a grinding contractor is hired. He stated that grinding operations would be budgeted to take place during the next fiscal year. To achieve compliance, Rockingham County must break the brush pile into smaller piles with fire lanes that allow sufficient access to emergency response personnel and equipment. 9. 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. 7904-MSWLF-1995, ATTACHMENT 3, PART V, Miscellaneous Treatment and Processing Unit Specific Condition #30 states, “Surface water shall be diverted from all operational and storage areas to prevent standing water in operational areas and under or around storage piles. Water that comes in contact with solid waste shall be contained on-site or properly treated prior to discharge.” Rockingham County is in violation of 15A NCAC 13B .0203(d) by allowing water to pond under and around wood waste storage piles. During the inspection, ponding water was observed at the base of the unprocessed wood waste stockpile on the northern and western sides. On the southeastern side of the stockpile, an area where vegetation peculiar to wetlands was observed. The presence of this type of vegetation would seem to indicate that the area is always wet. To achieve compliance, Rockingham County must perform maintenance to the wood waste area to prevent future ponding of water under and around wood waste storage piles located on the cap of a closed, unlined MSW landfill. Any water which comes into contact with waste must be collected and treated as leachate. 10. 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. 7904-MSWLF-1995, ATTACHMENT 3, PART V, Miscellaneous Treatment and Processing Unit Specific Conditions #35 and #36 state, “35. The facility is permitted to receive land clearing FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 13 waste as defined in 15A NCAC 13B, Rule .0101(23).” and, “36. The facility is permitted to receive wooden pallets constructed of unpainted and untreated natural wood.” Rockingham County is in violation of 15A NCAC 13B .0203(d) by accepting waste that the facility is not permitted to receive. During the inspection, painted wood, painted wood pallets and engineered wood were observed in the unprocessed wood waste stockpile. To achieve compliance, Rockingham County must remove all unacceptable waste from the unprocessed wood waste stockpile and dispose of it at a properly permitted facility. Proof of proper disposal must be presented to the Solid Waste Section for verification. Please note that the MSW landfill may not receive wooden pallets, per GS 130A-309.10(f)(12). 11. 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 is in violation of 15A NCAC 13B. 1626 (11)(c) by failing to collect and return all windblown material to the active landfill at the end of each day. During the inspection, a large amount of windblown material was observed along the access roadways, on the side slopes of the active landfill, in the sediment basins and in the trees and vegetation surrounding the active landfill. To achieve compliance, Rockingham County must collect and properly dispose of all windblown litter at the facility by the conclusion of each day of operations. Wood Waste Collection Area. Above: Wood waste stockpile. Right: Unacceptable waste - plywood, painted wood and painted pallets - throughout stockpile; ponding water at base of stockpile. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 13 ADDITIONAL COMMENTS 1. Operations at the facility consist of an active MSW landfill, currently operating in the Phase 3 Vertical Expansion, a scrap tire collection and processing area, white goods collection and processing area, a collection area for compressed gas containers, a convenience center for the drop-off of residential wastes and single stream recyclable materials, an electronics and television collection area, a wood waste collection and processing area, and an inert debris collection area. The site also contains a landfill gas to energy facility, operated by the county, and located adjacent to the leachate pond. 2. An inspection of all aspects of operations covered under Permit to Operate No. 7904-MSWLF-1995 was made on 12/13/2016. However, additional records were reviewed onsite on 12/16/2016. Preliminary corrective actions on the working face of the active landfill were also observed at the facility on this date. 3. The MSW landfill is permitted to receive waste generated within a 75-mile radius of the facility. Mr. Neugent stated that the county still limits the waste it accepts to that generated within Rockingham County. Records Review: 4. The current Permit to Operate (dated August 27, 2013) was available and reviewed. The operations plan (dated August 2012) was not on hand at the facility. Mr. Everhart was able to retrieve the document on his computer and print it out for everyone to review. Ensure that both the current Permit to Operate and the current Operations Plan are available at the facility and that facility staff are able to locate both documents as needed or upon request. 5. Tonnage reports for the facility were reviewed. Confusion about the various codes used to track each waste stream were cleared up through a phone call to the scale house operator. For the month of November 2016, the facility accepted 8,337.64 tons of waste for disposal; 150 gallons of used oil; and 209.43 tons of single stream recyclables, managed through a contract with Waste Management. Mr. Neugent stated that the average tonnage of waste received daily at the facility in November 2016 was 384.19 tons. 6. Open top scrap tire trailers are removed and replaced as they are filled. For the month of November 2016, records indicated a total of 163.45 tons of scrap tires were collected at the facility. Scrap tire certification forms were reviewed for completeness. Some of the forms were missing the range of dates during which the scrap tires were accumulated. The remainder of the required information was filled out on all of the forms. Ensure that each scrap tire certification form includes all required information prior to accepting the load. 7. White goods program records showed a total of 13.76 tons of white goods had been collected at the facility in November 2016. CFC removal and white goods recycling is handled through a contract with Foss Recycling. 8. The electronics and television recycling program is contracted through MeTech, Inc. 3.74 tons of electronics were received at the facility during November 2016. 9. A review of training records and certifications revealed the following personnel with current SWANA certificates:  Grandy Tuck, Landfill Operations Specialist – expires 11/12/2017 Windblown trash along access roadway and at toe of landfill. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 13  Steve Vernon, Landfill Operations Specialist – expires 03/24/2018  Facio Visaya, Landfill Operations Specialist – expires 03/24/2018  Toran More, Landfill Operations Specialist – expires 08/10/2019  Jacob Collins, Landfill Operations Specialist – expires 08/10/2019  Martie Neugent, Manager of Landfill Operations – expires 05/06//2017  Kathryn Jolly, Manager of Landfill Operations – expires 07/07/2019  Ronald Tate, Manager of Landfill Operations – expires 04/04//2019  Edward Shelton, Manager of Landfill Operations – expires 12/03//2018 10. Facility financial assurance has been received by the Solid Waste Section and is currently under review. 11. The facility has a Title V Air Quality Permit (Permit # 10200T02), issued and inspected by the Division of Air Quality. 12. The facility has a discharge permit to pump and haul leachate to the City of Eden’s waste water collection system in Wentworth from the leachate pond located on the southwest side of the active landfill. For the month of November, 2016, 152,144 gallons of leachate were hauled from the facility for disposal. 13. The facility is operated under an NC General Storm Water Permit, and is inspected by the Division of Energy, Mining and Land Resources. 14. The two latest semi-annual ground water monitoring records were reviewed. During the March 29-31, 2016 and the September 28-30, 2015 sampling events, 22 wells were sampled for the active MSW landfill, along with 4 surface water locations and 1 leachate location – the leachate pond. 15. Landfill gas monitoring records were reviewed for the facility. Sampling events occurred on 01/27/2016, 02/17/16, 03/15/2016, 04/08/2016, 07/13/2016 and 11/22/2016. Monthly sampling events had been undertaken to investigate the detection of methane exceedances in monitoring well M-6. The county is working with the Solid Waste Section Compliance Hydrogeologist to evaluate the situation. 16. Random waste screening logs were examined for the MSW landfill, indicating deficiencies in the number of screenings for the current calendar year. (See observed violation in this report for more information.) Active MSW Landfill (Phase 3 Vertical Expansion): 17. Current landfill operations were observed to be taking place in the Phase 3 Vertical Expansion. Remaining capacity in this cell is expected to last for an additional two years. 18. The working face of the landfill was observed to be very large with a lot of windblown trash migrating down the slopes and access road. Ensure that the working face is compact so that waste is easily controlled and windblown litter is kept to a minimum. (See observed violations in this report for more information.) 19. Inadequate cover on the working face as well as on large areas of the side slopes has led to unacceptable amounts of windblown litter around the site. Ensure that windblown litter is picked up daily, and that cover is adequate to reduce the incidence of windblown litter at the facility. (See observed violation in this report for more information.) 20. The facility is approved for the use of tarps for alternative daily cover, and Mr. Neugent stated that the county uses four 50’x100’ tarps as alternative daily cover. He also indicated that the working face had not been completely covered for a month or more. (See observed violation in this report for more information.) 21. The working face as well as the waste in areas surrounding the working face had inadequate cover, as did most of the slopes of the active landfill unit. Immediately cover all exposed waste in all areas of the facility. 22. Two equipment operators were observed on the working face, pushing and compacting the waste as it was being received. No spotter was at the working face to direct loads for tipping, and the tipping area did not appear to be well defined. Ensure that the tipping area is well defined and that sufficient traffic control is exercised to provide a safe and efficient working face at all times during facility operations. 23. On many of the side slopes of the landfill, poor waste coverage and serious erosion issues were seen to have resulted in the flow of sediment and waste downhill and into the storm water collection drains. Mr. Neugent explained that the dirt berm at the edge of the access roadway on the west side of the active landfill had been put into place to prevent sediment from crossing the road, running downhill over the grassy area between the roadway and the leachate pond, and into the leachate pond itself. (See observed violation in this report for more information.) 24. Please ensure that regular inspections and routine maintenance of the landfill slopes are performed as required. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 13 25. Internal roadways are of all-weather construction and well maintained 26. Most of the observed monitoring wells appeared to be properly labeled, locked and accessible. However, the hinge on MW4 was broken and, when observed, the well was open to the weather. Mr. Neugent stated that he would have the hinge repaired immediately. Please ensure that monitoring wells are inspected regularly to maintain the integrity of the wells and prevent the penetration of rain or animals. 27. The leachate pond and the leachate evaporation equipment were inspected. The liner of the pond was found to be partially covered with sediment, and the integrity of the liner could not be determined through observation. The permanent freeboard markings were not visible at the time of the inspection. Ensure that the pond liner is uncovered, cleaned of sediment and inspected regularly for tears and deterioration. 28. The leachate evaporation system remains in place in the leachate pond and is operated when weather conditions are optimal. Mr. Neugent stated that there had been little or no reduction in the amount of leachate pumped from the pond during periods of operation. White Goods Collection Area: 29. The white goods collection area is located atop one of the closed, unlined MSW landfill cells. As white goods are received, they are neatly stored upright on a concrete pad, thus preventing the crushing of gas lines and releases of CFCs. At the time of the inspection, the white goods collection area was observed to be clean and well maintained. 30. Currently, white goods and scrap metals are managed through outside contracts for CFC removal and recycling/disposal. Wood Waste Treatment and Processing Area: 31. The wood waste operations are also located atop one of the closed, unlined MSW landfill cells near the white goods collection area. Please note that the closed MSW landfill (permit #7901) was not inspected at this time. 32. Loads are screened as they come across the scales by the scale house operator, and those that are determined to be comprised of clean wood waste are directed to the collection area where customers unload. 33. As material accumulates, facility personnel push the wood waste into the pile and check for the presence of any unacceptable materials. The facility permit allows only for land clearing waste and unpainted natural wood pallets. During the time of the inspection, painted pallets, painted wood and plywood were observed throughout the large stockpile of unprocessed wood waste. Mr. Neugent stated that he was unaware that plywood was an unacceptable waste. (See observed violation in this report for more information.) 34. Wood waste is accumulated at the site until a contract for grinding is executed. Mr. Neugent stated that grinding occurs every other year. At the time of the inspection, the stockpile of wood waste was approximately 25’ high and 200’ long, varying in width from 20’ to 60’. Areas of ponding water were observed in several areas at the base of the pile. (See observed violations in this report for more information.) 35. Processed wood waste is stored in a location across the road from the convenience area. This area is also atop a closed, unlined MSW landfill cell where passive methane vents have been installed. The ground material is loosely configured in windrows and is not turned or monitored for temperature control. Another small pile of the mulch is located in a spot just south of the convenience area, behind the container storage area. Mr. Neugent stated that mulch is made available for purchase by the public. 36. Ensure that any processed wood waste offered to the public contains no engineered lumber/plywood and no painted or treated wood. Inert Debris Collection Area: 37. Used concrete and brick is stockpiled in an area adjacent to the white goods collection area. Loads determined by the scale house operator to contain only clean concrete are dumped here by customers, and facility personnel remove any unacceptable waste as the load is pushed into the stockpile. 38. Mr. Neugent stated that the pile was started with the goal of crushing the material to use as fill and roadway base throughout the facility. He explained that so far no crushing has occurred. 39. During the inspection, painted concrete, concrete with pipe and rebar protruding from the surface, plastic waste and wood waste were observed on top of the pile. These materials are not considered to be inert debris. 40. Ensure that only inert debris is stockpiled and crushed for use as fill material at the facility, and that any other waste is separated from each load and properly disposed of in the MSW landfill. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 13 Scrap Tire Collection Area: 41. Scrap tire disposal is contracted through Central Carolina Tire, and the contractor provides trailers which are removed and replaced as needed. The scrap tire collection area is located adjacent to the white goods collection area, atop one of the closed, unlined MSW landfill cells. 42. Scrap tire certification forms are collected at the scale house, and customers load tires directly into the trailers for disposal. 43. Two open top trailers were observed in the collection area and appeared to be in good condition. Tire trailers are positioned below grade to allow easy disposal from the concrete unloading area above. 44. The tire collection area provides ample space for the movement and positioning of trucks for unloading. Other Facility Operations: 45. A convenience area is operated near the scale house for residential drop-off of small vehicle loads of MSW, residential recyclables, electronics and televisions, used oil, and lead acid batteries. 46. The convenience area appeared to have adequate space for safe ingress, egress and traffic flow, and included concrete pads at the unloading points. The area was clean and well maintained, and staffed with an attendant during hours of operation. 47. The electronics and television collection area consists of a large concrete pad with a covered area where sorted, palletized materials are neatly stored awaiting transport. The adjacent open area serves as an unloading pad for use by the public. At the time of the inspection, the electronics area appeared clean and well maintained. 48. A landfill gas extraction plant, operated by the county, is located adjacent to the leachate collection pond. The plant is not currently in operation due to an inoperable engine, and the county is evaluating the efficacy of having repairs made in order to resume operations. When the plant was operational, the county sold power locally. During the time of the inspection, only the flare was in operation. 49. Additional research will be undertaken by the Solid Waste Section to determine the permitting history of the facility operations that take place on top of the closed, unlined MSW landfill cells, including the wood waste treatment and processing, scrap tire and white goods collection, and the convenience drop-off site. 50. During the inspection, a number of concerns, including inadequate coverage of waste, lack of maintenance and repair of landfill side slopes and cap, lack of established vegetative cover, excessive stockpiling of unsorted and unprocessed wood waste and used concrete, and lack of required maintenance in numerous areas of operation, were explained by facility staff as being due to insufficient personnel to manage and undertake these activities. Please note that 15A NCAC 13B .1604(2)(I) states: “Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures.” Sediment Basin No. 1 with significant sediment buid-up and windblown trash accumulated at the southwestern rim. Sediment Basin No. 2 with substantial sediment accumulation. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 13 Inert debris pile with unacceptable wastes integrated into the stockpile - painted block, plastics, concrete with rebar and metal pipe protruding from the surface. Above: Monitoring well 9 - properly labeled and locked, protected from damage by equipment and easily accessible. Right: Monitoring Well 4 - hinge broken and cover askew, open to the weather. White goods and compressed gas tank collection areas - clean and well maintained. Scrap tire collection area with open-top trailers - well maintained and easily accessible from loading dock. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 13 Please contact me if you have any questions or concerns regarding this inspection report. __________________________________________ Phone: 336-776-9672 Susan Heim Environmental Senior Specialist Regional Representative Sent on: December 22, 2016 to Lance Metzler, County Manager. X Email Hand delivery US Mail X Certified No. 70111570000185455905 Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Deb Aja, Western District Supervisor – Solid Waste Section Kim Sue, Environmental Senior Specialist – Solid Waste Section Ervin Lane, Hydrogeologist – Solid Waste Section Larry Frost, Permit Engineer – Solid Waste Section Jessica Montie, Compliance Officer – Solid Waste Section Ronnie Tate, Engineering & Public Utilities Director – Rockingham County Kathryn Jolly, Solid Waste Program Manager – Rockingham County Martie Neugent, Landfill Supervisor – Rockingham County 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. Convenience area - staffed and well maintained, with ample room for vehicle traffic and maneuvering to drop-off points. Electronics drop-off area - sorted, palletized electronics stored under cover with open drop-off area adjacent; convenience area in background.