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HomeMy WebLinkAbout7904_INSP_20181030FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 8 UNIT TYPE: Lined MSWLF X LCID YW X Transfer Compost SLAS COUNTY: Rockingham Closed MSWLF X HHW White goods X Incin T&P FIRM PERMIT NO.: 7904 CDLF Tire T&P / Collection X Tire Monofill Industrial Landfill X DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: October 30, 2018 Date of Last Inspection: June 13, 2018 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 Kathryn Jolly, Environmental Compliance Solid Waste Program Manager – Rockingham County Lee Hill, Environmental Senior Specialist – 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 Expired August 27, 2018; permit renewal request currently under review by the Solid Waste Section. PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS: None FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 8 ADDITIONAL COMMENTS 1. The permit for this facility includes the following operations: active MSW landfill, scrap tire collection, white goods collection and processing, compressed gas cylinder collection, electronics and TV collection, wood waste collection and processing, inert debris collection and processing, and a convenience center for the drop-off of residential wastes and single stream recyclable materials. 2. A landfill gas plant owned and operated by the county is located on the southeast side of the leachate pond. The plant is not currently producing electricity, and all gas is routed to the flare. 3. The MSW landfill is currently operating in the Phase 3 vertical expansion. Construction of a new cell will begin within the next six months in the old borrow pit located southeast of the current active landfill. It is anticipated that waste will be directed to the new phase sometime in 2019 or 2020. Records Review: 4. The current Permit to Operate (August 27, 2013) and approved Operations Plan (revised August 2012) were available at the landfill office. The permit expired on 8/27/18, but the renewal request is under review. 5. Tonnage reports for MSW waste were not available during the inspection, but were provided via email by Ms. Jolly following the inspection. The reports can be summarized as follows:  July 2018 – 8,525.47 tons of MSW received for landfill disposal;  August 2018 – 9,003.93 tons of MSW received for landfill disposal;  September 2018 – 7,954.31 tons of MSW received for landfill disposal. These monthly tonnage figures total 25,483.91 tons of MSW received at the facility for the first quarter of the current fiscal year. Leachate is pumped and hauled by CTW in Greensboro, through a contract with the county. The facility has a discharge permit to pump and haul leachate to the City of Eden’s waste water collection system in Wentworth. 6. Leachate pump and haul records were not available onsite during the inspection. However, Mr. Neugent provided these records via email following the inspection. These records yielded the following information:  January through April 2018, no leachate was hauled for disposal;  May 2018 – 128,927 gallons of leachate were hauled to the City of Eden for disposal;  June 2018 – 171,689 gallons of leachate were hauled to the City of Eden for disposal;  July 2018 – 74,558 gallons of leachate were hauled to the City of Eden for disposal;  August 2018 – 378,219 gallons of leachate were hauled to the City of Eden for disposal;  September 2018 – 474,294 gallons of leachate were hauled to the City of Eden for disposal. The total leachate hauled from January through September 2018 was 1,227,687 gallons. Mr. Neugent pointed out that additional leachate was hauled in September to draw down the pond in preparation for Hurricane Florence and Tropical Storm Michael. 7. The facility is operated under an NC General Storm Water Permit and several approved erosion control plans. Mr. Neugent stated that the Division of Energy, Minerals and Land Resources inspector assigned to the facility had indicated his intention to combine the various erosion control plans into one plan that covers the entire facility. Mr. Neugent further stated that he had not been given a time frame for this action, nor any indication of what it might entail. 8. Groundwater monitoring records for the facility were provided for review in digital form at the facility, and indicated that sampling was being conducted semi-annually, as required. Reports were reviewed for the second sampling event of 2017 and the first sampling event of 2018. The second sampling event of the previous year took place October 23 – 25, 2017, with some resampling done on December 12, 2017. Exceedances were 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 3 of 8 reported in all closed areas of the landfill and also in the active lined landfill unit. The first sampling event of this year took place April 2 – 5, 2018. No exceedances were reported in Areas 1 through 4, and exceedances appeared to be continuing a gradual decline in Area 5. Results for the active landfill seemed incongruous with the history of the site, so resampling was done May 16-17, 2018. Most of the exceedances seen in the April sampling event were refuted by the May results; however, exceedances were still reported for the active landfill. Alternate Source Demonstrations have been performed to try to eliminate the landfill as the cause of some of the exceedances. The county continues to work closely with Solid Waste Section Hydrogeologist Ervin Lane to isolate the source of the exceedances detected throughout the facility’s monitoring network. 9. Landfill gas monitoring records for the facility were also provided in digital form, and confirmed that sampling events are conducted quarterly as required. Due to the level of exceedances found, the county undertook monthly monitoring during the second quarter of the year, with sampling taking place April 20, 2018, May 16, 2018, and June 15 and 18, 2018. Exceedances continued to decline in these sampling events, so quarterly monitoring resumed on July 25, 2018. The latest sampling event took place on September 25, 2018 and also showed exceedances. 10. Records of the monthly flare inspections, conducted by the county’s contractor, Joyce Engineering, were reviewed and verified for the 2018 calendar year. 11. Semi-annual inspections of the leachate sumps are conducted for the county by Reynolda Electric. Records provided by Mr. Neugent after the inspection indicated that the latest leachate sump inspection took place on June 28, 2018. Mr. Neugent stated that he was waiting to hear back from the contractor to schedule a date, but he expected that the next regular inspection would take place in November 2018. 12. Random waste screening records for the current calendar year are maintained at the scale house. These records were reviewed, and it was confirmed that these random load inspections take place at the rate of one per week. Log sheets were found to be neat and properly filled out. However, a review of the operations plan indicated that at least one waste screening is required per week, but that at least 1% of the waste received at the facility, by weight, must be screened. The scale house operator reviewed the weight tickets from the past several weeks and estimated that the facility averages between 80 and 100 loads per weekday, at an average of 350 tons per weekday, with much less waste being accepted on Saturdays. Based on these estimates, it was determined that a minimum of six load inspections per week must be performed in order to comply with the terms set forth in the county’s operations plan. Random waste screening frequency will be revisited during the permitting process in order to clarify the county’s waste screening procedures in the revised operations plan. 13. Records of gas well tuning and inspection were reviewed for 2018 and found to be complete. 14. Scrap tire program records were available for inspection at the scale house. A review of Scrap Tire Certifications received during the month of October was conducted, and all appeared to be complete. 15. The county contracts with New River Tire to handle recycling and disposal of its scrap tires. Tonnage records for the scrap tire program for the current fiscal year indicated that 132.97 tons had been received in July, 104.9 tons in August and 162.07 tons in September, totaling 399.94 tons for the first quarter. 16. The county contracts with Foss Recycling to handling recycling of its white goods and scrap metal. CFC evacuation takes place at the county facility and is performed through a county contract with Rapid Recovery. A review of program records revealed 72 tons of white goods and 30.4 tons of scrap metal were collected during the first quarter of the current fiscal year. 17. Electronics and televisions are recycled through a county contract with Synergy Electronics Recycling. Program records for the first quarter of the current fiscal year indicated that11.616 tons of electronics and televisions had been transported from the facility by the recycling contractor during that period. 18. A review of training records and certifications indicated that the following personnel have current certifications:  Facio I. Visaya – SWANA Manager of Landfill Operations – expires 6/14/2021;  Edward Shelton – Joyce Engineering Certified Landfill Manager – expires 12/3/2018;  Martie Neugent – SWANA Manager of Landfill Operations – expires 7/7/2019;  Toran Moore – NCSWANA Landfill Operations Specialist – expires 8/10/2019;  Jacob Collins – NCSWANA Landfill Operations Specialist – expires 8/10/2019;  Kathryn Jolly – SWANA Manager of Landfill Operations – expires 7/7/2019. 19. The issue of the availability of facility operating records, program records, plans and permits was discussed during previous inspections and in previous inspection reports. This information shall be assembled into an FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 8 operating record and maintained so that is it available for review by facility staff when needed and by Solid Waste Section staff when requested. Ensure that a copy of the facility operations log (operating record), including but not limited to all of the records listed in comments 4-18, is assembled and maintained at the facility either in digital or hard copy form and can be made available for review upon request. Field Inspection: 20. The cap of the active landfill was inspected and found to be in good condition for the most part. Several areas had been damaged by Hurricane Florence and Tropical Storm Michael. However, the erosion that had taken place produced only small rills that did not expose waste. Mr. Neugent stated that he was making repairs when conditions were dry enough to permit equipment to operate on the slopes without causing further damage. Slopes with intermediate cover supported established vegetation that appeared to have survived the storms intact. Mr. Neugent pointed out several areas where matting had been staked down to fill in bare spots that had washed during these heavy rain events. Most of the matted areas were beginning to show signs of new green growth. 21. The top of the landfill cap held several piles of asphalt millings that had been obtained from a nearby NCDOT project for the purpose of constructing and filling facility access roadways. Mr. Neugent stated that the remaining mulch/soil mix that had been used as alternative cover material had been exhausted. Equipment ruts were apparent in several areas of the landfill top where water was ponding.  Immediately reshape the top of the landfill to eliminate water being impounded over waste.  Ensure that maintenance is performed on the top of the landfill to fill in equipment ruts, restore the crown to ensure the sheet flow of storm water, and reseed to re-establish a stable vegetative cover. 22. No leachate seeps were evident on the landfill slopes. Mr. Neugent pointed out one area on the northeast slope that staff was monitoring carefully. On inspection, the area was dry, and no discoloration of the ground was evident. But vegetation had died in two separate spots, so monitoring seemed to be a prudent decision. 23. A new haul road had been constructed leading from the southeastern corner of the landfill to the working face. The roadway was of all-weather construction and in good condition. Drainage ditches along the side of the road appeared to be functioning properly, and no erosion was evident. 24. The working face was located on the south side of the haul road near the top of the landfill. The working face was long and very close to the haul road. Uncovered waste was visible in the operational area around the working face, where equipment had churned it up from beneath the soil cover. An inspection of the area found that ample soil cover had been applied. Some of the equipment ruts were estimated to be 14” deep and entirely made of soil. Working face operations were observed, and it was noted that the loader and the compactor maneuvered throughout the operational area surrounding the working face frequently, thus causing waste to be uncovered. Mr. Hill asked Mr. Neugent if he had a fill sequence or plan. Mr. Neugent stated that he had thought the equipment operators would have been operating in an area higher on the landfill that morning. He added that the fill sequence was determined by conditions on the landfill and the expected weather for the operating day. The following procedures are recommended:  The loader and compactor operators should confine their movement to areas within the working face as much as possible to avoid churning up waste in the area surrounding the working face.  Landfill staff operating at the working face should be briefed about the location, size and area of the working face in advance of the start of daily operations by the landfill manager. This allows the landfill manager to control operations, make critical decisions about procedures and staffing, and develop a fill plans for the current operational area. Ensure that all waste is covered at the end of every operating day. This includes waste caught in and around the wind fencing, tarp equipment, and on and around the haul road. This is a statutory requirement that must be met, and landfill staff must plan the workday to ensure that ample time remains to apply adequate cover to all waste before shutting down operations. 25. An equipment operator was observed tracking in cover on the side slope to the north of the working face with excellent results. On departure from the working face, the side slope had been completed with a smooth, stable grade, and no waste was visible. 26. Mowing operations had begun to take place. Most of the closed landfill areas had been mown and appeared to FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 8 be in good condition with well-established vegetation. Some areas of the active landfill had also been mown and bush-hogged. In areas where mowing had not yet taken place, small trees and woody growth were evident. Mr. Neugent stated that he is the only staff member currently possessing the experience and expertise needed to mow the landfill slopes. He added that mowing the entire facility can take him up to two months to complete.  It is recommended that additional facility staff be trained to handle mowing operations.  Ensure that small trees and woody growth are removed from the cap of both the active and closed landfill areas. 27. The wood waste collection and processing area was found to be in good condition and well-maintained. Clean lumber and pallets had been separated from the vegetative wood waste, and adequate fire lanes had been incorporated into the stockpile area. Facility staff stated that most of the brush pile had accumulated as a result of the recent hurricanes. The wood waste area was free from ponding water, and no unacceptable materials were observed. 28. The scrap tire collection area was clean; however, several hundred tires were piled on the ground surrounding the trailers. Facility staff explained that some issues had arisen with having full tire trailers pulled and replace in a timely manner. Mr. Neugent stated that he had been in contact with New River Tire to address the problem, and that service had begun to improve. He added that tires had not been allowed to accumulate on the ground for more than a day or two. 29. The white goods collection and processing area was well-maintained, and units containing CFCs were staged upright in a manner that would easily accommodate evacuation of the refrigerants. Empty compressed gas tanks are collected on the cement pad adjacent to the white goods area. These tanks are also collected and recycled by the county’s white goods and scrap metal contractor, Foss Recycling. 30. Inert debris is separated and stockpiled in the same operating area as the wood waste, white goods and tires. No unacceptable materials were observed in the inert debris stockpile. 31. A convenience site for county residents, located just inside the scale house gate, is manned during operating hours. The site was observed to be clean and well-maintained, with adequate space for vehicles to maneuver. 32. South of the convenience site a compactor is staged where residents may drop off household recyclable materials. The electronics collection area is situated next to the recyclables compactor and provides an open area where residents may easily drop off electronics and televisions. Facility staff sort, stack and palletize electronics and televisions and store them on a covered concrete pad. The electronics area was found to be clean and well-maintained, as was the roll-off container storage area located just to the south. 33. All of the following facility operations are located atop closed landfill units: white goods and scrap metal; wood waste; scrap tires; inert debris; convenience center; electronics; and, container storage. These operations, their locations and their operating procedures will be incorporated into the new facility permit and operations plan. 34. Several landfill gas and groundwater monitoring wells were observed during the inspection, and all were found to be in good condition and easily accessible. 35. The measuring rod in the leachate storage pond indicated that approximately 3 feet of freeboard was available. The pond was surrounded by thick vegetation that obscured the view of the edges. Please perform maintenance around the leachate pond to remove vegetation and provide access so that staff may visually inspect on a regular basis. 36. The sediment basin located to the south of the landfill office and shop had been cleaned and drawn down during the spring. The basin appeared to be in good condition. Mr. Neugent stated that he planned to clean out the basin on the northeast side of the active landfill within the next six months. 37. Slope drains and ditch lines were observed to be clean and functional. Mr. Neugent stated that the installation of additional slope drains had made a tremendous difference in the stability of the landfill slopes. He added that one or two more may be installed if needed. 38. Facility access roadways are of all-weather construction and in good condition. The main perimeter roadway is asphalt, and had been repaved the previous spring. Gravel sections of the road were free from dust, and no erosion was evident. 39. The entire facility was found to be clean. Windblown litter was minimal and well managed. Mr. Neugent pointed out several part-time staff working on litter pick-up in the operating area near the working face. He stated that litter collection takes place every weekday during operating hours. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 8 i A view of the white goods/scrap metal area from the inert debris stockpile. The area is clean and white goods are neatly staged. Note the woody vegetation on the landfill slope in the background. Maintenance has been performed on closed Area 3. Vegetative cover is in good condition, and no woody growth is evident. A view of the leachate pond. Note the weeds and brush growing up around the banks. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 8 The working face is densely compacted. Churned up waste is evident in the operational area surrounding the working face. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 8 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: November 7, 2018 to Ronnie Tate. X Email Hand delivery US Mail Certified No. [ _] Copies: Deb Aja, Western District Supervisor – Solid Waste Section Larry Frost, Permit Engineer – Solid Waste Section Ervin Lane, Hydrogeologist – Solid Waste Section Lee Hill, Environmental Senior Specialist – Solid Waste Section Martie Neugent, Landfill Supervisor – Rockingham County Kathryn Jolly, Environmental Compliance Solid Waste Program Manager – Rockingham County Clean soil has been tracked into the side slope of the active landfill adjoining the working face.