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Home My WebLink About7904_INSP_20170725FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 12 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: 07/25/2017 Date of Last Inspection: 06/27/17 and 0705/2017 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: Ronnie Tate, Engineering and Public Utilities Director Telephone: 336-342-8104 (office) – 336-634-7111 (mobile) Email address: rtate@co.rockingham.nc.us FACILITY CONTACT ADDRESS: P. O. Box 132 Wentworth, NC 27375 PARTICIPANTS: Martie Neugent, Landfill Supervisor – Rockingham County 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. Based on the county’s corrective action plan, the working face and all exposed waste at the facility will be adequately covered by June 30, 2017, and covered daily at the end of each operating day thereafter. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 12 Landfill operations were observed at the working face for about an hour, beginning at approximately 4:20 pm. The operational area is currently situated in a bowl, which aids in containing windblown litter and in establishing a clearly defined tipping area. The working face was again found to be compact and well controlled, as it was during the previous inspection on July 5, 2017. This is a major improvement over the large working face observed during the comprehensive inspection on December 13, 2016. Landfill staff covered the working face with two sections of tarp, using a tarp-o-matic. After the tarp had been successfully applied, an equipment operator worked to push clean soil onto the areas immediately surrounding the tarp. Mr. Neugent stated that the equipment operator is undergoing training to learn how to control and cover the working face during daily operations. He added that the edges of the tarp are weighted with metal chains so that it will remain anchored in a wind of up to 45 mph. At approximately 5:15 pm, the equipment operator parked the loader and left the operations area. At this time, uncovered waste and inadequately covered waste were visible in some areas surrounding the tarp and in the operations area in general. Mr. Neugent stated that he was working with staff to improve waste coverage, especially at the end of the day. However, operational areas surrounding the working face were again observed to be lacking the 6” of earthen material that constitutes adequate daily cover. Please note that all waste received for disposal during the operating day must be completely covered at the end of that operating day; and, any waste from previous operating days that is disturbed and uncovered must have new cover applied. No waste should be visible at the end of the operating day. This means that soil must be placed on top of any waste surrounding or projecting from under the tarp and on top of any waste uncovered as a result of daily operations in the operating/tipping area surrounding the working face. It is recommended that soil be pushed up to or over the edge of the tarp around the entire margin to ensure adequate coverage of all waste, and that after the working face is covered correctly, soil is then placed over any visible waste in the operating/tipping area. A great deal of progress was observed to have taken place with regard to slope repairs. A large percentage of the southern slopes had been covered, regraded, seeded and mulched since the previous inspection on July 5, 2017. As a result, some of the areas were now well covered, where adequate coverage of waste had been a concern previously. However, portions of the slopes surrounding current operations area and the working face were again observed to be lacking the 6” of cover required. A follow-up inspection will be made to determine that all waste on the working face and surrounding operational areas, on side slopes and the across the entire landfill unit, is being adequately covered at the end of every operating day to resolve this violation. Working face being compacted prior to tarp application. Soil is stockpiled at the bottom of the lift to help confine waste. (Photo taken by S. Heim 7/25/17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 12 Working face with tarp applied. (Photo taken by S. Heim 7/25/17.) Close-up view of uncovered waste at corner of tarp. This is an example of one of several areas of uncovered waste at the edge of the tarp that were observed during the inspection on July 25, 2017. (Photo taken by S. Heim 7/25/17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 12 2. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(a) cited for failing to prevent silt from leaving the MSWLF facility. As previously stated in #1 above, major progress had been made in repairing and stabilizing side slopes. In addition, the perimeter drainage ditch on the southeastern side of the landfill had been rip- rapped and matted, and check dams had been installed at regular intervals along the ditch line. Several other portions of the ditch had been rip-rapped and were awaiting the installation of matting. In some spots, the ditch was observed to be almost flat, and sediment had covered over the matting and some had flowed out onto the access roadway. Protection for a stormwater inlet had been installed; however, it appeared that the upslope side of the inlet remains unprotected, and that silt fence is missing from the drainage ditch entry points on both sides of the inlet. As a result, sediment was accumulating in and around the inlet. The area where the access roadway had been undermined by runoff water had been filled with rock and a slurry of crushed rock designed to harden in place. Final paving repairs to the roadway had been completed in this area as well. Close-up view of uncovered waste in the operating/tipping area near the working face. (Photo taken by S. Heim 7/25/17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 12 Slope repairs underway: soil cover being applied and smoothed into place on the southeastern side of the landfill above stormwater inlet. (Photo taken by S. Heim 7/25/17.) A portion of side slope that had been repaired, seeded and mulched. Note drainage ditch repairs underway; a rip- rapped section leads to a section being cleaned out in preparation for rip-rap. (Photo taken by S. Heim 7/25/17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 12 View of the southwestern side of the landfill. Access roadway to the right leads to the working face, which can be seen in the background. The slope in this area has been repaired and seeded. Ditch repairs have not begun here, and some sedimentation is visible around the toe of the landfill. (Photo taken by S. Heim 7/25/17.) A portion of the drainage ditch on the southeastern side of the landfill that had been cleaned out and covered with matting, with a check dam installed at left. The ditch appears to be flat, with no depth for handling the flow of water. (Photo taken by S. Heim 7/25/17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 12 Protection installed around stormwater inlet. Grates are in place over the drains. Sediment covers the incoming ditch and collects in and around the inlet. (Photo taken by S. Heim 7/25/17.) Stormwater inlet: no protection on upslope side of inlet; sediment buildup at entry points of drainage ditch; sediment accumulating in and around the drains. (Photo taken by S. Heim 7/25/17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 12 3. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(b) cited for failing to prevent on-site erosion. No erosion was visible in areas where slope seeding and mulching had taken place. Some slopes were in the process of being repaired and regraded and, for the most part, evidence of erosion was still apparent, especially near the toe of the slopes. It is recommended that mulch or hay be applied to unrepaired slopes as an interim measure to help the ongoing curb erosion. Several new slope drains have been installed and some existing slope drains have been repaired and/or repositioned. Mr. Neugent stated that work is beginning on the construction of slope berms. He explained that the plan is to create two berms on each slope, one positioned higher and one positioned lower, to help manage the flow of surface water. Based on the revised corrective action plan submitted by Joyce Engineering, surface water diversion berms and slope drains will be constructed, and repairs will be made to the existing perimeter drainage ditch by mid-September 2017. Unrepaired slope on the north side of the landfill. Note erosion rills containing uncovered waste and flat drainage ditch with sediment covering matting. (Photo taken by S. Heim 7/25/17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 12 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. New vegetation was in evidence on some of the previously seeded slopes. However, most areas have required repairs and reseeding. Mr. Neugent stated that seeding was scheduled to take place at least every two weeks until complete. Newly seeded slopes have been mulched to hold the seed in place and to protect new vegetation as it sprouts. Based on the revised corrective action plan submitted by Joyce Engineering, temporary seeding will be applied to the side slopes between now and mid-September, with permanent seeding scheduled to take place by September 30, 2017. 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. The wood waste storage area was observed. It appeared as though approximately half of the wood waste stockpile had been ground, and the processed material piled in the open area to the west. No fire lanes had been cut into the pile, and engineered wood was still visible in the unprocessed stockpile. Grinding equipment was in evidence, however no processing operations were taking place at the time of this inspection. Ronnie Tate, Director of Engineering and Public Utilities, stated prior to the inspection that grinding operations were expected to be complete in approximately two weeks. 6. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0203(d) cited for accepting waste that the facility is not permitted to receive. During this inspection, large pieces of plywood and fiberboard were again observed on the wood waste stockpile. Compliance cannot be demonstrated until the existing wood waste pile containing the unacceptable material is removed and disposed of properly. Repaired section of drainage ditch with no slope berm above. Note sediment accumulating on top of the newly placed matting in the perimeter ditch and flowing out of the ditch onto the access roadway. (Photo taken by S. Heim 7/25/17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 12 During this inspection, a scrap tire was observed near the toe of the working face. When I returned to the working face, the tarp had already been pulled over this area. Mr. Neugent stated that he felt sure the tire had been removed before the tarp had been applied. Ensure that landfill staff are trained to know and recognize wastes that are banned from landfill disposal; that loads are adequately screened to identify unacceptable materials; and, that procedures are in place to remove and segregate unacceptable materials for proper disposal at a facility that is permitted to receive them. 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. Additional progress had been made throughout the facility since the previous inspection on July 5, 2017. Temporary staff are still being used to collect windblown waste. The area on the opposite site of the access road from the working face had been partially covered with clean soil. Mr. Neugent explained that this area was being regraded in order to address a large leachate seep that had been found and repaired the previous week. As a result, the problem with windblown litter had been significantly reduced along the access to the working face. However, during this inspection, windblown trash was observed throughout the facility, predominantly in areas where slope repairs had not yet been initiated. Windblown litter must be collected and returned to the working face at the end of each operating day. 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. No leachate seeps were observed during this inspection. 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. Initial sampling has taken place. Rockingham County must continue to work with Mr. Lane to monitor and resolve any issues relating to the leachate collection system and leachate breakouts, and to undertake any corrective actions that may be required. View of the access roadway leading to the working face, which is visible in the upper left of this photo. The accumulation of windblown trash can be observed along this entire stretch of access road. (Photo taken by S. Heim 7/5/17.) Same view of access roadway with the working face visible at the center background of this photo. Much of the windblown litter along this roadway has been either collected and disposed of or covered with clean soil. (Photo taken by S. Heim 7-25-17.) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 12 OBSERVED VIOLATIONS: No additional violations were observed during this inspection. ADDITIONAL COMMENTS 1. The revised corrective action plan, submitted by Joyce Engineering and dated June 22, 2017, was being implemented at the site. See the Status of Past Observed Violations section of this report for more detailed information about steps being taken to bring the facility into compliance. 2. Current landfill operations were observed to be taking place in the Phase 3 Vertical Expansion. 3. The working face was again observed to be compact and well-controlled. Ensure that the working face and all waste received during daily operations is covered with at least 6” of clean earthen material or approved alternate daily cover at the end of every working day. 4. Additional compaction of the working face may be necessary to ensure that the waste disposal area is relatively level and there is no protruding waste that could cause damage to the tarp. (See photo in Status of Past Observed Violations #1 above.) 5. Grinding equipment was observed to be staged in the wood waste collection area. Approximately half of the wood waste stockpile had been processed, and a large stockpile of processed material was staged near the equipment. 6. Plywood sheets and other engineered lumber were still visible throughout the unprocessed wood waste pile. 7. The inert debris stockpile had increased in size and included a large pile of used asphalt. Ensure that any painted or treated concrete is removed from the inert debris storage and operations area and properly disposed of by the end of every working day. 8. Mr. Neugent stated that the road repaving project had been completed at the facility. The area of roadway that had been undermined by runoff appeared to have been repaired and restored. 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 12 of 12 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: August 2, 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 Jenny Johnson, Director of Operations – Joyce Engineering Ervin Lane, Compliance 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