7904_INSP_20170309

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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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: 03/09/2017 Date of Last Inspection: 02/02/2017

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: [phone]
Email address: [e-mail]

FACILITY CONTACT ADDRESS:
P. O. Box 132
Wentworth, NC 27375

PARTICIPANTS:
Martie Neugent, Landfill Supervisor – Rockingham County
Larry Frost, Permitting Engineer – 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 Phase 3 Vertical Expansion: Issued August 27, 2013
Permit Expires August 27, 2018

PURPOSE OF SITE VISIT:
Partial Inspection

STATUS OF PAST NOTED VIOLATIONS:

1. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(2)(a) cited for failure 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 working face was observed to be compact, and soil was being stockpiled for use
in providing daily cover along with the tarps that were also staged in the area.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 5

2. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(a) cited for failing to prevent silt from
leaving the MSWLF facility. Repairs on the side slopes were close to completion, and Mr. Neugent stated that a
seeding contractor had been chosen and was ready to begin work upon notification that repairs were finished.

3. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(b) cited for failing to prevent on-site
erosion. As previously stated, slope repairs were underway at the time of this inspection. Some small areas of
erosion were observed in areas where slope repairs had not yet been completed.

4. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(c) cited for 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. A contract for seeding has been awarded, and work will take place upon
completion of the slope repairs.

5. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0203(d) cited for storing wood wastes in a single
large pile with insufficient fire breaks and lanes. Mr. Neugent stated that a contract for wood waste processing and
removal had been awarded, and that the contractor has been asked to proceed as soon as possible.

6. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0203(d) cited for accepting waste that the facility
is not permitted to receive. During the previous inspection, painted wood, painted wood pallets and engineered
wood were observed in the unprocessed wood waste stockpile. Most of this unacceptable material had been
removed, and Mr. Neugent stated that the remainder of the wood waste would be ground for use as boiler fuel and
removed from the site. As stated in #5 above, a grinding contract has been awarded and will be executed as quickly
as possible to eliminate the issues with the wood waste storage area. Compliance will be demonstrated when the
existing wood waste pile containing the unacceptable material is removed and disposed of properly.

7. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(11)(c) cited for failure to collect and return
all windblown material to the active landfill at the end of each day. During this inspection, additional progress was
observed to have been made regarding collecting windblown trash throughout the facility. Portable windscreens
were staged effectively at the working face. A clean-up crew of 3 was observed collecting windblown trash on the
side slopes, both by hand and using the waste-vac system, and bags full of litter were staged along the access
roadway. Mr. Neugent stated that facility staff stop by to collect the bags throughout the day and take them to the
working face for proper disposal. He added that he had been provided with an inmate labor crew to assist with the
clean-up effort. Mr. Neugent stated that his crews had been working on the slopes where repairs were being
completed, and that he would have the litter crews shift focus to the access roadway leading to the working face.

SUMMARY:
All slope repairs and seeding must be completed and all exposed waste covered by April 14, 2017. Solid Waste
Section staff will make additional inspections to ensure that the work has been accomplished as required.

OBSERVED VIOLATIONS:
No additional violations were observed during this inspection.

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
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ADDITIONAL COMMENTS

1. Current landfill operations were observed to be taking place in the Phase 3 Vertical Expansion.
2. The working face of the landfill was inspected and found to be small, with an adequate tipping area for trucks to
enter, dump and exit safely.
3. Portable windscreens were placed in the area of the working face to limit windblown trash. The cap surrounding the
working face had been repaired and covered, although some waste was still visible. Ensure that the entire
working face and the area surrounding it is adequately covered, and that all windblown trash is collected at
the end of each day of operation.
4. The facility is approved for the use of tarps as alternative daily cover. Mr. Neugent and Mr. Frost discussed the
potential for using autofluff as an alternative daily cover. The landfill is currently receiving multiple loads of
autofluff daily from Foss Recycling in Reidsville. Mr. Frost explained that autofluff is currently an approved
alternative cover material, and advised Mr. Neugent to submit an email request that could be added to the permit
record before beginning use of the autofluff.
5. It is recommended that an operating log be started in which the type of cover used on each operating day and
the specific dates that the required 6” soil cover is applied to the working face in lieu of alternative daily
cover.
6. On the top of the active landfill, dump truck traffic involved with slope repairs had caused ruts to form, and waste to
become uncovered. Mr. Neugent took immediate action to direct dump trucks to bring soil to the area and
equipment to level and spread the soil to ensure adequate cover for the waste. After the inspection, Mr. Neugent
provided photos of the landfill top showing that the ruts had been eliminated and adequate coverage had been
applied. (See photos below.)
7. During this inspection, some lower areas of the slopes were still undergoing repair and additional cover was being
applied in preparation for seeding.
8. Internal roadways are of all-weather construction. The collapsed area of pavement along the edge of the roadway
that surrounds the MSW landfill, that was observed during the previous inspection, had not been repaired at the time
of this inspection. The area remained coned off, and Mr. Neugent explained that roadway repairs would take place
after slope seeding is completed. In this way, the drainage and erosion issues above the roadway that had caused the
collapse will be eliminated in advance of the repair work.
9. At the time of this inspection, drainage ditches were still being cleared of sediment as the slopes above them were
being repaired. Progress has been made since the previous inspection, and Mr. Neugent stated that he hoped to be
ready for seeding within the next two weeks.
10. A small leachate seep was observed on the eastern slope of the landfill. Mr. Neugent stated that his equipment
operator had already been notified about the area and repairs would be completed before the end of the operating
day.
11. The inert debris collection area was observed to be free from unacceptable waste.
12. The large wood waste pile was still present on top of the closed landfill Area IV (Permit No. 79-01). Mr. Neugent
stated that the wood grinding contract had been awarded and work would commence as soon as the contractor
mobilizes onsite. Mr. Frost asked if there was any record of approval from the Solid Waste Section for conducting
wood waste and other operations on top of closed landfill areas. Mr. Neugent stated that he was not aware of any
such documentation.
13. All groundwater monitoring wells and some of the methane monitoring wells and landfill gas extraction wells were
observed during this inspection. Repairs are currently underway to ensure that all wells are properly tagged and
cover locks and hinges are functioning properly.
14. The outlet for a French drain that extends under the landfill liner was observed near groundwater monitoring well
19. Mr. Neugent explained that this site was being sampled for an alternate source demonstration. Post-inspection,
Mr. Frost consulted with Ervin Lane, Solid Waste Section Compliance Hydrogeologist responsible for reviewing
the alternate source demonstration. Mr. Frost will make a determination as to any corrective actions that may be
required relating to the French drain and the leachate collection system.
15. While in the area of the leachate collection pond, Mr. Frost inquired about the leachate evaporation system that was
in place. Mr. Neugent stated that leachate is sprayed from the nozzles in the pond and the large fan positioned at the
northeast edge of the pond helps dry the leachate aerosol mist before it settles back into the pond. He added that the
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 5

system can only be used on rare occasions when the wind is calm enough to prohibit the leachate from travelling to
the surrounding vegetation. The leachate evaporation system should not be operated until an operation plan
for the system is submitted to and approved by Mr. Frost.
16. After speaking with Solid Waste Section hydrogeologists post-inspection, Mr. Frost determined that the existing
groundwater monitoring plan was not up to date and the current landfill gas monitoring plan was incomplete.
17. After examining facility and Solid Waste Section records, no closure permit or post-closure plan for the closed,
unlined MSW landfill was found.
18. The current approved Operations Plan, revised August 2012, does not include all of the operations that occur at the
facility, such as the collection of televisions and computer equipment, nor does it identify the areas dedicated to
specific facility operations.
19. The current facility Permit to Operate expires August 27, 2018, and the request for permit review and renewal is
required to be submitted to the Solid Waste Section by February 27, 2018. Along with the request, the following
will be required:
a. An updated, comprehensive Operations Plan, including all approved alternative cover materials and
leachate collection system maintenance program;
b. A site map, which delineates the areas dedicated to specific facility operations;
c. A comprehensive facility groundwater monitoring plan (covering both 79-01 and 79-04); and,
d. A comprehensive facility landfill gas monitoring plan (covering both 79-01 and 79-04).
A closure permit with closure conditions for the closed, unlined MSW landfill (Permit #7901) will be included in
the new permit.

Leachate seep on eastern slope of landfill. French drain outlet near MW-19.
Slope repairs complete, slope drains installed.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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Please contact me if you have any questions or concerns regarding this inspection report.

__________________________________________ Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative

Sent on: March 22, 2017 to
Lance Metzler, County
Manager.
X Email Hand delivery US Mail Certified No. [ ]

Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section
Deb Aja, Western District Supervisor – 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