7904_RockinghamMSWLF_INSP_FID1285377_20190219

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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
X
LCID
YW
X
Transfer
Compost
SLAS
COUNTY: Rockingham
MSWLF
PERMIT NO.: 7904
Closed
X
HHW
White
X
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
Tire T&P/
X
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: February 19, 2019
FACILITY NAME AND ADDRESS:
Rockingham County Landfill
281 Shuff Road
Madison, NC 27025
Date of Last Inspection: January 28, 2019
GPS COORDINATES: N: 36.36455 ° W: 79.84336 °
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Ronnie Tate, Engineering and Public Utilities Director
Telephone: [phone] (office) — 336-634-7111 (mobile)
Email address: rtate(cr�,co.rockingham.nc.us
FACILITY CONTACT ADDRESS:
P. O. Box 132
Wentworth, NC 27375
PARTICIPANTS:
Edward Shelton, Acting Landfill Supervisor — Rockingham County
David Giachini, Permitting Engineer — Solid Waste Section
Chuck Kirchner, 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:
Partial Inspection
STATUS OF PAST NOTED VIOLATIONS:
None
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FACILITY COMPLIANCE INSPECTION REPORT
DE Q Division of Waste Management
Nor Solid Waste Section
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .1626(11)(c) states, in part: "At the conclusion of each day of operation, all windblown
material resulting from the operation shall be collected and returned to the area by the owner or operator."
Rockingham County is in violation of 15A NCAC 13B. 1626 (11)(c) by failing to collect and return all
windblown material to the active landfill at the end of each day.
During the inspection, a large amount of windblown material was observed along the access roadway leading to
the working face and on the side slopes of the active landfill.
To achieve compliance, Rockingham County must collect and properly dispose of all windblown litter at
the facility by the conclusion of each day of operations. Compliance must be demonstrated by March 6,
2019. A follow-up inspection will be performed to verify compliance.
A view of the southwestern slope of the landfill with the working face above (left). Excessive windblown litter is
visible across the entire slope.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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A view of the
south side of the
working face
access roadway
with the
northeast side
slope adjacent to
the working
face, seen at
right.
Windblown litter
is pervasive, as
confirmed by
the presence of
the seagull
flock.
A view of the
southwestern
side slope
looking west
toward the
leachate storage
pond. In this
area, windblown
litter includes a
50 gallon plastic
barrel (top
middle).
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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.
ADDITIONAL COMMENTS
1. This site visit was made for the purpose of conducting a routine field inspection of the facility. No facility
operating records were reviewed.
2. All photos included in this report were taken by Susan Heim during the inspection on February 19, 2019, unless
otherwise noted.
3. The working face was observed to be small and appeared to be well compacted.
4. During the previous inspection on January 28, 2019, the operations area surrounding the working face was
extremely wet, and trucks had been observed struggling to maneuver in 12 — 15 inches of mud in the tipping
area. During this inspection, it was obvious that facility staff had implemented recommendations to place
additional rock and soil in this area to help mitigate the effects of the mud. Trucks were seen driving on a wet
but well -packed surface and maneuvering safely in the small, tight tipping area.
5. A large volume of uncovered waste was observed in the tipping/operations area surrounding the working face.
Some of the uncovered waste had mixed with the cover soil, and trucks could be seen leaving the tipping area
with waste stuck in the treads of their tires and around their wheel wells. Soil cover in this area was not
sufficient. Ensure that soil cover is applied throughout each operating day as necessary so that waste is
confined to the working face, as required by 15A NCAC 13B .1626(2)(a).
Uncovered waste
is visible
throughout the
operations area
surrounding the
working face.
This photo
clearly shows the
lack of sufficient
soil cover in this
area.
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FACILITY COMPLIANCE INSPECTION REPORT
EQ Division of Waste Management
NIF Solid Waste Section
6. During the inspection of the working face, a truck was observed dumping a load that included two white goods
units. Mr. Shelton instructed his staff to set the white goods aside so that they could be taken to the white goods
collection area at the end of the operating day.
7. At the same time the load containing white goods was dumped, a roll -off truck backed in to the tipping area
with what appeared to be a load of wood pallets. The pallets were pointed out to Mr. Shelton, and he was
advised not to allow the roll -off truck to dump his load. Mr. Shelton approached the roll -off truck and spoke
with the driver, then allowed the load to be dumped. When questioned, Mr. Shelton stated that the majority of
the load was treated lumber. Upon inspection of the load, Mr. Shelton was advised to remove the pallets so they
could be taken to the wood waste collection area. Facility staff pulled approximately 10 pallets out of the load
by hand and set them to the side. At the bottom of the load, two over -sized plastic -covered pallets were found,
and Mr. Shelton was advised that these also must be removed. After some discussion, facility staff removed the
heavy plastic covering, leaving it to be pushed into the working face, and hand -carried the oversized pallets
away from the tipping area.
A roll -off truck containing pallets and two white goods (left) were observed at the working face.
8. Some additional discussion ensued concerning pallets mixed in a C&D waste load. Please refer to the following
general statute for clarity: §130A-309.10(f) states, in part, "No person shall knowingly dispose of the
following solid wastes in landfills: (12) Wooden pallets, except that wooden pallets may be disposed of in
a landfill that is permitted to only accept construction and demolition debris." Because this facility is not
permitted as a C&D landfill that only accepts construction and demolition debris, this exception does not apply.
9. When asked about training for landfill operators, Mr. Shelton stated that all staff are trained regularly about
unacceptable materials and landfill procedures.
10. When asked, Mr. Shelton explained that the usual procedure for inspecting random loads of waste is for the
scale house operator to call the working face with information about a load to be screened; landfill staff then
perform the screening at the working face and phone in details to the scale house operator; the waste screening
log is completed by the scale house operator and signed by the landfill operator at the conclusion of the working
day.
11. Mr. Shelton was then asked to perform a waste screening of one of the incoming loads. He notified the scale
house with information about the next truck that approached the working face. Once the load had been dumped,
the truck was allowed to leave, and Mr. Shelton began walking around the pile of waste and texting information
about its contents to the scale house operator. After being advised to do so, Mr. Shelton called the loader
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FACILITY COMPLIANCE INSPECTION REPORT
EQ Division of Waste Management
NIF Solid Waste Section
operator over and had him push the waste pile over. While more of the contents of the waste pile were now
visible, this maneuver was not sufficient to enable Mr. Shelton to thoroughly inspect all material in the load. In
order to completely inspect a load of waste, the pile must be spread out and waste pulled apart so that all
materials are presented in a single layer and any unacceptable waste is evident and easily documented and
removed. Improvement in waste screening techniques is needed. Please revise waste screening procedures
to ensure that all material in each randomly selected load is inspected.
12. Facility staff were observed applying clean soil cover to portions of the landfill top and side slope near the
working face. Mr. Shelton stated that this work would continue during operating hours until all landfill slopes
were repaired and adequately covered.
13. The side slopes of the active landfill were observed and, in general, those with an established vegetative cover
appeared to be in good condition. Some areas had been covered with matting to stabilize the slope.
14. Slopes with a soil cover or newly sprouted vegetative cover appeared to have been damaged by rain and snow.
Some erosion rills were visible along the working face access road and along the northern and eastern slopes of
the active landfill. Mr. Shelton stated that continuous storm events have largely prevented the use of equipment
on the slopes to effect repairs. He added that, when slope conditions permit, repair work resumes.
15. Because it is required by 15A NCAC 13B .1626(2)(a), ensure any waste that becomes exposed as a result
of erosion or facility operations is completely covered by the end of every operating day. If the use of
heavy equipment is not possible due to slope conditions, alternative methods of providing cover must be
explored. For example, a small utility vehicle might be an effective means of bringing soil to problem
areas without causing additional damage to the slope.
Uncovered waste
was observed on
the side slope south
- of the working
- face.
''•••C a
16. A well drilling crew was observed working on top of the active landfill northwest of the working face. The
landfill cap appeared to have been damaged by heavy equipment. Deep ruts were evident throughout this area,
and water had been impounded in these ruts as well as along the northern berm of the landfill top. Ponding
water appeared to be in excess of a foot deep in spots. The slope drain located on the north corner of the landfill
top did not appear to be functioning, since water could be seen ponding around it. Concerns about ponding
water in this area were raised during the October 30, 2018 inspection of the facility, and immediate action was
requested. It does not appear that any repair work was undertaken since that time. 15A NCAC 13B .1626(8)(b)
states, "Surface water shall not be impounded over or in waste." Ensure that maintenance is performed
to restore the landfill cap, eliminate ponding water and allow the slope drains to function properly.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A view of the northern end of the top of the active landfill where water is ponding in equipment ruts
and along the berm. A slope drain is located near the bottom right corner of the photo.
17. Facility access roadways are of all-weather construction and were found to be in good condition.
18. During a previous inspection conducted on October 30, 2018, concerns about the maintenance of the leachate
storage pond were discussed. During this inspection, it appears that no additional maintenance had been
performed on the leachate pond since that time. The grass and woody vegetation that has grown up around the
edge of the pond make it difficult to determine where the edge of the pond liner is located and whether or not it
is intact. As a result, the amount of freeboard in the pond cannot be accurately confirmed. Please perform
maintenance necessary to demonstrate that the required 2' of freeboard is present in the leachate storage
pond.
19. In the summer of 2017, after the discovery of leachate leaving the landfill by means of a french drain located
near monitoring well MW-19, Rockingham County installed two temporary leachate holding tanks to capture
the liquid. One tank was removed when the flow of leachate from the drain slowed. The remaining tank has
been in use since that time and will be removed once the expanded leachate collection system that will
encompass the new Phase 4 construction is complete and functioning. During this inspection, the tank and
feeder pipe were observed to be damaged. No information was provided as to when the damage occurred. The
top of the tank had been crushed and the pipe broken off so that it is no longer actually connected to the tank.
Some leachate appeared to be trickling into the holding tank, but it is unclear as to whether or not a leachate
release occurred as a result of the damage sustained.
To remain in compliance, Rockingham County must immediately contact SWS Hydrogeologist Ervin
Lane to discuss corrective actions required, including but not limited to the repair or replacement of the
temporary holding tank and piping, the proper means to anchor the tank in place, and a plan for any
sampling that might be necessary to assess damage to the environment.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
The temporary leachate holding tank was crushed by the steel guard rail that had been put into place to keep the tank
from floating. When the top of the tank collapsed, the port that had held the collection pipe changed position and, in the
process, caused the pipe to break. Note the 2"x4" used to prop up the pipe so that it can reach the mouth of the holding
tank, and the break in the pipe. The inset photo above (taken on 8-25-17 by S. Heim) shows the original tank
installation.
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FACILITY COMPLIANCE INSPECTION REPORT
DE Q Division of Waste Management
NIF Solid Waste Section
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan
Heim
d Susan Heim,
o=Solilid Waste Section, ou,
email=susan.heim@ncdenr
.gov, c=US
Date: 2019.02.27 16:07:10
-05'00'
Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: February 28, 2019 to
X
Email
Hand delivery
US Mail
Certified No. 11
Ronnie Tate.
Copies: Deb Aja, Western District Supervisor — Solid Waste Section
Larry Frost, Permit Engineer — Solid Waste Section
David Giachini, Permit Engineer — Solid Waste Section
Ervin Lane, Hydrogeologist — Solid Waste Section
Chuck Kirchner, Environmental Senior Specialist — Solid Waste Section
Edward Shelton, Acting Landfill Supervisor — Rockingham County
Kathryn Jolly, Environmental Compliance Solid Waste Program Manager — Rockingham County
Jenny Johnson — Joyce Engineering
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