7904_INSP_20170427

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 5

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: 04/27/2017 Date of Last Inspection: 03/09/2017

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 controlled. Because of severely
muddy conditions that resulted from heavy rains, equipment was dredging up waste that had been previously
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 5

covered. Mr. Neugent stated he was working carefully with loaders and trucks to get sufficient soil to all areas
surrounding the working face, and operators were observed reshaping the muddied areas of the landfill.

2. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(a) cited for failing to prevent silt from
leaving the MSWLF facility. Slopes had been repaired, graded and seeded, as required. Recent heavy rains had
caused some damage to the slopes and repairs were observed to be underway. Reseeding will be necessary to
establish a vegetative cover sufficient to prevent silt from leaving the facility.

3. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(b) cited for failing to prevent on-site
erosion. After a week of heavy rain, some areas needed repair and regrading, and additional seeding will be required
to ensure the establishment of the vegetative cover necessary to prevent erosion

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. Regrading and seeding had been accomplished at the facility as required. However,
heavy rains over the previous week had washed away a large percentage of the seed and newly sprouted vegetation.
For the most part, damage to the slopes was minor, and it was evident that slope repairs and the addition of slope
drains had prevented major erosion. Repairs were underway again at the time of this inspection, and Mr. Neugent
stated that reseeding will take place as soon as they are completed.

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. No changes had been made in the size of the stockpile, nor had any
fire lanes been added. However, processing operations were beginning during this inspection.

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. During this inspection, the wood grinding contractor arrived onsite to begin operation. It is
anticipated that all the wood waste, including the processed wood waste stockpile, will be removed from the facility
within the next two weeks. 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, windblown trash was
observed to have been greatly diminished since the previous inspection on 3/9/17. Mr. Neugent stated that inmate
labor crews and temporary labor were still working daily at the task, and that he hoped to have covered the few
remaining areas needing attention within the next week. Vegetative growth had been removed from areas where
significant amounts of trash had been accumulating, thus making it easier to keep the facility clean.

SUMMARY:

Mr. Neugent stated that slope repairs will continue and reseeding will occur as soon as feasible and conditions
permit. He also stated that litter crews will continue to work daily to eliminate the remaining accumulation of
windblown trash at the facility.

OBSERVED VIOLATIONS:

1. 15A NCAC 13B .1626(8)(d) states, in part: “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
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 5

discharge.”

Rockingham County is in violation of 15A NCAC 13B .1626(8)(d) by failing to contain leachate within a
lined disposal cell or leachate collection and storage system or to treat it prior to discharge.

During this inspection, Mr. Neugent pointed out several leachate seeps along an area of the south slope of the
active MSW landfill. Repairs to these areas had begun. However, at two specific locations, leachate was observed
leaving the liner and running directly into the drainage ditch. Mr. Neugent was instructed to take immediate steps
to stop the leachate from leaving the liner, and to affect repairs as quickly as possible.

To achieve compliance, Rockingham County must contact Ervin Lane, Solid Waste Section Hydrogeologist,
at 919-707-8288 within five (5) days of receipt of this report to present a sampling plan that shall be
implemented immediately upon his approval to evaluate the extent of any potential environmental impact
resulting from these leachate releases. The results of this evaluation will dictate any additional corrective
measures to be required. Please see the attached Notice of Violation letter for additional information about
required corrective measures.

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
maneuver safely. Because the working face is close to the edge of the liner, please ensure that waste remains
within the lined area and that no damage to the liner occurs because of daily operations.
3. The cap surrounding the working face had been damaged by heavy rains, and waste was visible through the mud.
Ensure that the entire working face and the area surrounding it is adequately covered at the end of every
operating day.
4. The facility is approved for the use of tarps as alternative daily cover. Following the previous inspection, Mr.
Neugent requested approval to use autofluff as an alternative daily cover as well. Mr. Frost responded to the request
with his approval on 3/13/17 and, as a result, autofluff has been used regularly as alternative daily cover since that
time. Please ensure that the documentation required in Mr. Frost’s email of 3/13/17 is noted in the facility
operating record and available for review upon request.
5. It is recommended that an operating log be kept 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. The collapsed area of pavement along the edge of the roadway that surrounds the MSW landfill, that was observed
originally on 2/2/17, had not been repaired at the time of this inspection, and the undermined area appeared to have
increased. Cones were staged along the roadway. Mr. Neugent reiterated his plan to affect repairs after slope
seeding is completed. In this way, the drainage and erosion issues above the roadway that caused the collapse will
be eliminated in advance of the repair work.
7. Mr. Neugent pointed out two areas where leachate seeps had popped up along the lower slope berm after the week
of heavy rains. During the inspection of these seeps, two streams of leachate were observed leaving the lined area
and entering the drainage ditch. See Observed Violations section of this report for additional information.

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 4 of 5

View of northeast slope of
active landfill. Slope
repairs, grading, seeding
and slope drain
installation was completed
prior to the April 14, 2017
compliance deadline.
Damage to newly seeded slope caused by heavy rains two days
prior. Erosion is evident.
View of the top of the active landfill with repairs in progress.
Heavy rains caused soil cover to wash and create ponding.
LEFT: Leachate seeps along
lower berm of landfill slope.
RIGHT: Leachate seep
entering drainage ditch.
LEFT: Additional
undermining of the
roadway has occurred.
RIGHT: Ponding water on
top of active landfill where
repairs are underway.
Waste is being relocated to
the working face.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 5

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: May 2, 2017 to Lance
Metzler, County Manager.
X Email Hand delivery US Mail X Certified No.
7011 1570 0001 8545 5950

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