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.