7904_INSP_20170523

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 6

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: 05/23/2017 Date of Last Inspection: 04/27/2017

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
Kathryn Jolly, Environmental Compliance Solid Waste Program Manager – Rockingham County
Ronnie Tate, Director of Engineering and Public Utilities – Rockingham County
Butch Joyce, President – Joyce Engineering
Mousa Maimoun, Project Consultant – Joyce Engineering
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

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 6

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 inspected and found to be spread out and very large. The
working face area that had been observed during the previous inspection on April 27, 2017 was found to be lacking
adequate cover during this inspection; and, waste was observed to be exposed. At the time of this inspection, landfill
equipment operators were working to apply soil cover to some areas of the active landfill. It is noted that the issue
of adequate daily cover was pointed out during the comprehensive inspection on December 13, 2016 and
reflected in the Notice of Violation issued on December 22, 2016. Policies and procedures must be enacted
immediately to address the issue of adequate daily cover and provide adequate staff and resources to
accomplish this required task and demonstrate compliance with 15A NCAC 13B .1626(2)(a). If this matter is
not adequately addressed, the county may be subject to tiered enforcement.

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. Rain had caused additional
damage to the slopes since the previous inspection on April 27, 2017. Erosion and sedimentation were observed,
and the ditch line at the toe of the active landfill was full of sediment and debris in many areas. Additional grading
and slope maintenance, in addition to reseeding in some areas, 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. Additional repair and maintenance work had been performed on the slopes of the active landfill since the
last inspection on April 27, 2017. However, the slopes had not been stabilized to the point of being able to handle
the additional rainfall that had occurred. Erosion was observed in many areas of the landfill slopes, and
additional seeding will be required to establish the stable 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. Although regrading and seeding had taken place on the active landfill, the slopes
were not stable enough to remain intact through the recent rain storms. Some areas of the slopes were green with
sprouted vegetation, but the seed had been washed away from large areas of the slopes, especially in the lower
levels, where large rills containing uncovered waste were visible. Mr. Neugent stated that repair work would
continue so that reseeding could take place as soon as possible.

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. It appeared that the size of the wood waste stockpile had increased
since the previous inspection on April 27, 2017, and no fire lanes been added. The grinding operations that had been
observed being set up on April 27th had ceased and the equipment had been removed from the site. Mr. Neugent
explained that the paving company, responsible for making repairs and repaving the access roadways, had moved
into the facility and removed the paving in some areas. Rather than have the grinding equipment damage the
exposed roadbed in the unpaved sections of roadway, he stated that he had asked the grinding contractor to return
after the paving crew had finished their work.

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 on April 27, 2017, a few pieces of painted wood, painted
wood pallets and engineered wood were observed in the unprocessed wood waste stockpile. During this inspection,
large pieces of plywood and fiberboard were observed on the pile. Because the grinding contractor had left the site,
it is unclear how quickly the large stockpile of wood waste will be removed from the site. Compliance cannot be
demonstrated until the existing wood waste pile containing the unacceptable material is removed and
disposed of properly.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 6

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 diminished again. Mr. Neugent stated that inmate labor crews and temporary labor were still
working daily at the task.

8. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(8)(d) cited for failure to contain leachate
within a lined disposal cell or leachate collection and storage system, or to treat all leachate prior to discharge.
During this inspection, the trenching that had been observed during the April 27. 2017 inspection, along the slopes
of the active landfill in the area of the leachate breakouts remained, and it appeared that trenches had also been dug
in the remaining locations where leachate had been found on the surface. However, these trenches had been left
open and uncovered waste was observed in them. In addition, a new seep area was observed near the end of the row
of trenches. Mr. Neugent stated that he had noted the new seep earlier and had instructed his crew to begin repairs
on the slope in that location as well.

As required, Rockingham County had submitted a sampling plan to Ervin Lane, Solid Waste Section Compliance
Hydrogeologist, who approved the plan and directed that it be carried out. Ms. Jolly stated that the sampling had
taken place and results are awaited.

OBSERVED VIOLATIONS:

No additional violations were observed during this inspection.

ADDITIONAL COMMENTS

1. Prior to the inspection of the active landfill, a meeting was held in the landfill office at the request of Joyce
Engineering. Those present at the meeting were Butch Joyce and Mousa Maimoun, both of Joyce Engineering;
Kathryn Jolly, Ronnie Tate and Martie Neugent, all with Rockingham County; and, Larry Frost and Susan Heim,
representing the Solid Waste Section. The meeting was requested by Joyce Engineering in order to review the
pending violations and the county’s plan for coming into compliance.
2. At the conclusion of the meeting, Mr. Joyce stated that he would provide a plan for achieving compliance that will
include a timeline for completion.
3. Current landfill operations were observed to be taking place in the Phase 3 Vertical Expansion.
4. The working face of the landfill was inspected and found to be spread out and very large. Several facility staff were
observed to be hauling soil and placing cover to try to contain and control the area.
5. The working face area that had been observed during the April 27, 2017 inspection was found to be lacking
adequate cover at the time of this inspection. This area is very close to the edge of the liner. The uncovered waste
made it difficult to determine whether or not waste had remained inside the liner and whether or not the liner had
been damaged. (See photos below.)
6. Mr. Neugent stated that he was still having difficulty covering all exposed waste at the end of each operating day.
7. The contractor had begun work removing the asphalt on the access roadways in preparation for repaving. Cones
were still staged along the roadway where the pavement had collapsed as a result of the erosion on the landfill slope
above.
8. The grinding contractor that had begun staging equipment in the wood waste collection area during the April 27,
2017 inspection had removed his equipment and postponed work until after the paving was completed, at Mr.
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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Neugent’s request.
9. The wood waste stockpile was observed to contain plywood sheets and other engineered lumber that had not been
present during the April 27, 2017 inspection.
10. Repairs to leachate seeps had not been completed, and open trenches were observed along the slopes which
contained exposed waste. It must be assumed that these trenches were left unprotected during the several days of
rain that had taken place over the previous week. (See #8 under Status of Past Noted Violations in this report for
additional information.)

Rain damage to newly seeded slope observed during April 27,
2017 inspection. (Photo taken 4/27/17 by Susan Heim.)
Rain damage to landfill slopes as observed on May 23, 2017.
Some newly sprouted vegetation remains.
Close-up view of erosion rill on landfill slope. Note exposed
waste.
View of previous working face area with uncovered waste
clearly visible. Note edge of waste marker in left foreground
and sediment clogged drainage ditch.
LEFT: View of the old working face area as new soil cover is being added. RIGHT: Closer view of the area, with the old working
face in the foreground and the current working face in the background.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 6

Leachate seep area with open trench and exposed waste. Leachate seep with open trench and exposed waste. Note
exposed waste on left that has been washed down the hill, and
the puddled liquid and sediment in the clogged drainage ditch
in the foreground.
TOP and BOTTOM: Row of trenches where repairs to leachate seeps had begun. Note exposed waste in
trenches and on the slope; and, liquid and sediment clogging the drainage ditch.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 6

PLEASE NOTE: All photos shown above were taken by Susan Heim on May 23, 2017, unless otherwise noted in the
individual photo caption.

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 30, 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
Butch Joyce, President – Joyce Engineering
Mousa Maimoun, Project Consultant – Joyce Engineering
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