7904_INSP_20200312

NORTH CAROLINAD_E Q��
OepeNnenf of Envlronmmbl 0uel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
X
LCID
YW
Transfer
Compost
SLAS
COUNTY: Rockingham
MSWLF
PERMIT NO.: 7904-MSWLF-1995
Closed
HHW
White
X
Incin
T&P
X
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
Tire T&P/
X
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: March 12 and June 23, 2020 Date of Last Inspection: October 22, 2019
FACILITY NAME AND ADDRESS:
Rockingham County Landfill
281 Shuff Road
Madison, NC 27025
GPS COORDINATES: Lat: 36.36455 o Long: 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, Landfill Supervisor — Rockingham County (3/12/20 and 6/23/20)
Kathryn Jolly, Environmental Compliance Solid Waste Program Manager — Rockingham County (3/12/20 and 6/23/20)
Ronnie Tate, Director of Engineering and Public Utilities — Rockingham County (3/12/20 and 6/23/20)
Joe Ryder, Site Supervisor — LaBella Engineering (3/12/20 only)
David Giachini, Permitting Engineer — Solid Waste Section (3/12/20 only)
Jason Watkins, Field Operations Branch Head — Solid Waste Section (6/23/20 only)
Susan Heim, Environmental Senior Specialist — Solid Waste Section (3/12/20 and 6/23/20)
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 Phases 1, 2 and 3 Vertical Expansion — LIFE OF SITE: Issued April 12, 2019
Permit to Construct Phase 4 Lateral Expansion: Issued April 12, 2019
PURPOSE OF SITE VISIT:
Partial Inspection
Page 1 of 11

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
STATUS OF PAST NOTED VIOLATIONS:
A. CORRECTIVE MEASURES IN PROGRESS: 15 A NCAC 13B .1626(2)(a) states, in part: "the owners or
operators of all MSWLF units must cover disposed solid waste with six inches of earthen material at the end of
each operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing
litter, and scavenging."
A great deal of progress had been noted during the March 12, 2020 inspection concerning covering and repairing
the eroded slopes of the active landfill where closure operations had been taking place. During the June 23, 2020
inspection, it was noted that side slopes in the closure area had been seeded and a vegetative cover had been
established. Several large erosion rills were observed in separate areas of the southwest slope.
A large erosion rill was observed on the southern slope of the landfill next to the former working face access
roadway. The rill followed the path of a slope drain and had eroded to the point of uncovering waste on the slope.
A pile of uncovered waste was observed at the bottom of this slope on the corner of the access roadway during
both the March 12 and June 23, 2020 inspections. An uncovered area of waste was also observed on a portion of
the southern slope located directly above the south end of the new Phase 4 cell.
Uncovered and churned up waste was observed in the former operating area on top of the landfill where the
previous working face had been located. The area appeared to be in much the same condition on June 23, 2020 as
it had on March 12, 2020.
While observing the current working face in the northern area of the new Phase 4, Mr. Watkins pointed out areas
along the interior side slope where waste had accumulated a few feet up the slope, above where the soil cover had
been placed. Mr. Watkins stated that working face procedures must be modified to ensure that all waste is
covered. In addition, he noted that there was a significant amount of waste that had been allowed to accumulate in
and around the tarp roller that was located on the floor of the current operations are that must be managed daily as
well.
To achieve compliance, Rockingham County must ensure its daily operating procedures include the
following:
• Cover all waste in and around the working face with at least 6" of clean soil or approved alternative
cover material at the end of every operating day;
• Collect and remove all waste from machinery and equipment, including wind fence, tarps and
rollers, compactors and loaders;
• Inspect the access roadway and all areas of the landfill cap and slopes to ensure that no waste has
been tracked or blown away from the working face, and that no waste has been uncovered as a
result of equipment operating outside of the working face, or as a result of erosion.
Mr. Watkins also stated that the following actions and repairs must be completed prior to the end of the
current operating day (June 23, 2020):
• Cover the exposed waste, repair the large erosion rill, and properly install the slope drain on the
south slope below the previous disposal area;
• Collect and properly dispose of the pile of waste adjacent to this same slope drain;
• Cover the area of exposed waste located on the south slope directly above the southern end of the
new Phase 4;
• Properly cover all of the waste around the edges of the current working face.
Page 2 of 11

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
Ms. Heim requested that photos be provided showing that these actions had been completed, and Mr. Shelton
agreed to do so. The following is a series of photos detailing the uncovered waste observed and the corrective
actions that have been taken.
M
�X
Above: Uncovered waste in the operations area surrounding the working face in this photo provided by Edward Shelton at
the end of the operating day following the March 12, 2020 inspection.
Below: Waste on top of the previous phase of operations, uncovered as a result of vehicle and equipment maneuvering.
Accumulated waste is also visible in and around the wind screens and equipment stored in this area. (Photo taken by S.
Heim during the June 23, 2020 inspection)
Page 3 of 11

NORTH CAROLINAD_E Q��
OepeNnenf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
These 3 photos show the slope drain and erosion rill. Above
right photo provides a gauge as to the depth of the rill and
the waste it has uncovered. Left photo shows the pile of waste
below the rill. (Photos taken by S. Heim during the June 23,
2020 inspection.)
erosion rill has been repaired,
slope drain properly installed,
the pile of waste removed.
9to taken by Edward Shelton at
?nd of the operating day on
�/20.)
Page 4 of 11

NORTH CAROLINAD_E Q��
OepeNnenf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Uncovered waste was visible beyond the edge of the daily soil cover and around the tarp rolls during the June 23,
2020 inspection. (Photo taken by S. Heim 6123120)
Clean soil cover has been extended to address the uncovered waste that had
accumulated beyond the edge of cover. (Photo taken by Edward Shelton following
the inspection on 6123120)
Page 5 of 11

NORTH CAROLINAD_E Q��
OepeNn.nf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Area of uncovered waste on the south slope directly above the southern end of the new Phase 4 cell. No
comparative photos appear to have been provided by Mr. Shelton after the inspection. (Photo taken by S. Heim
6123120)
Please provide photographs that show this area has been properly covered and repaired as required.
OBSERVED VIOLATIONS:
None.
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. The partial facility inspection on March 12, 2020 was performed to follow up on concerns cited during the
previous inspection on October 22, 2019, and to conduct a pre -operations inspection of the completed Phase 4
construction in advance of granting approval to operate.
2. The additional inspection conducted on June 23, 2020 was performed to observe operations in the northern cell
of the new Phase 4, and to ensure that additional concerns raised during the March 12, 2020 inspection had been
properly addressed.
Inspection of Phase 4 Construction:
3. Phase 4 is designed in a dogleg shape that parallels and wraps around the southeastern end of the active Phase 3
disposal area. The dogleg is sloped with a high area located near the elbow curve so that the cell drains toward
both the northern and southern ends in opposite directions.
Page 6 of 11

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
4. On March 12, 2020, the inspection began at the southwest end of the new cell, where a sump, cleanout pipe and
control panel for the leachate pump are located. The operation of the control panel and alarm system were
discussed. Some concerns arose concerning the need for facility staff training in the operation of the system and
concerning the development of procedures to ensure the regular inspection of the system and documentation of
those inspections in the facility operating record.
5. Mr. Giachini expressed his concern about the pump access, pointing out that it appeared to be below grade level
and questioning how leachate would be contained in the event of a backup in the system or intrusion of storm
water into the pipe. Mr. Giachini noted that other access manholes in Phase 4 also appeared to be constructed at
or below grade level.
6. Mr. Giachini asked whether the leachate collection lines had been video inspected, adding that he had not seen a
report in the CQA package. Mr. Kemppinen stated that this procedure had unintentionally been omitted and that
he would take measures to ensure it was undertaken and completed as quickly as possible. Ms. Heim added that
the county had also not provided documentation of the required video inspection of the remainder of the
leachate lines in Phases 1, 2 and 3 of the facility, which had been requested in the report covering the previous
inspection on October 22, 2019.
On March 27, 2020, the Solid Waste Section received correspondence from Mr. Kemppinen that included a
report covering the video inspection of all Phase 4 leachate lines which occurred on March 18, 2020. Discussion
following receipt of the correspondence confirmed that the Phase 1, 2 and 3 leachate lines had also been video
inspected and a report would be forthcoming. As of the date of this report, the Section has not received this
report. It has been conveyed to the Section that LaBella is working to remedy discrepancies in the video
inspection report and the information contained in the approved facility plans.
7. The cell was lined with a layer of gravel, and some water was observed to be ponding at both the southern and
northern ends of the new disposal area.
8. A rip -rapped drainage ditch had been constructed along the outside perimeter of the new cell, and white
marking posts were located along the top of the berm above the ditch line to permanently delineate the edge of
the disposal area.
9. It was noted during the March 12, 2020 inspection that edge of waste markers that had been removed for the
partial closure construction. During the June 23, 2020 inspection, all edge of waste markers appeared to be in
place as required.
10. During the March 12, 2020 inspection, the permanent leachate storage tank and pump system had not yet been
installed east of the new cell to replace the temporary system that had been installed in 2017 to capture the
leachate flow from the underdrain. On June 23, 2020, the permanent leachate tank and pump system were
observed to be in place and operational. Significant erosion was evident in the area where the new system had
been installed, and the access roadway was not navigable by vehicles. Mr. Watkins expressed his concern about
the stability of the slope and access road in this area and asked what plans were in place to address the issue and
to ensure the integrity of the new pump system. Mr. Tate stated that this is one of the items that remain on the
final punch list for Shamrock, the contractor for the Phase 4 construction.
Although the new system had been installed, Mr. Shelton stated that the temporary leachate tank system had not
yet been emptied and removed. Please provide a timetable for the removal of the temporary leachate
storage tank system and the proper disposal of the leachate contained in it.
11. During the March 12, 2020 inspection, Mr. Kemppinen asked if the county could designate half of the new cell
to be filled first, leaving the other half without waste, and therefore generating no leachate. He stated that a
ridge had been incorporated into the design that separates the two halves of the cell where the drainage divides.
Mr. Giachini stated that the ridge was not obvious, and he explained that a design and operating procedures
would be required prior to approval in order to ensure both the proper operation of the new phase and an
effective separation between leachate and storm water. Following the inspection, Mr. Kemppinen worked with
Mr. Giachini to develop an acceptable means of separating the two areas of the new cell. During the June 23,
2020 inspection, landfill operations were taking place in the northern half of the new cell. The ridge had been
Page 7 of 11

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
built up and further identified with a series of orange and white traffic barrels enabling equipment operators to
maintain a safe distance from this demarcation point in the cell.
Inspection of Phases 1, 2 and 3:
12. During the March 12, 2020 inspection, the approved closure work on the slopes of the active landfill was nearly
complete. The slopes appeared to be a patchwork of green, where newly planted vegetative cover had begun to
emerge, and brown, where additional soil had been applied to the slope to repair areas damaged by erosion. The
soil -covered areas looked stable and ready for seeding. Small erosion rills were observed on the lower portions
of the slopes in most of the green areas. Mr. Shelton acknowledged that additional repairs and ongoing
maintenance would be required to establish a vegetative cover and prevent the slopes from washing in future
rain events.
13. During the June 23, 2020 inspection, vegetative cover on the closed areas of Phases 1-3 had become well
established. However, several large erosion rills were evident in separate areas of the southwest slope. Please
ensure that repairs are affected to the southwest slope now to prevent waste from becoming exposed;
and, that new erosion rills are repaired as they become visible in the future. (See Status of Past Noted
Violations section of this report for additional information.)
14. The leachate storage pond appeared to be nearing capacity during the June 23, 2020 inspection. Two tanker
trucks were observed pumping leachate from the pond for transport to the City of Eden wastewater treatment
plant for proper disposal. Mr. Shelton stated that the heavy rains that had been occurring over the past several
weeks had necessitated regular pumping and hauling of the leachate from the pond.
15. During the March 12, 2020 inspection, windblown litter was observed in many areas of the side slopes adjacent
to the working face. Windblown litter management had greatly improved by the June 23, 2020 inspection. Two
temporary workers were observed collecting trash on the outer slope of the new cell.
16. Areas of uncovered waste were visible in several spots around Phases 1-3 during both the March 12 and June
23, 2020 inspections. (See Status of Past Noted Violations section of this report for additional information)
17. The working face was located on top of Phases 1-3 at the time of the March 12, 2020 inspection. The access
roadway to the working face was very steep but navigable, opening onto a tipping area observed to be of
adequate size to allow a truck to maneuver and discharge its load safely. The working face was small and Mr.
Shelton stated that he works with equipment operators daily to ensure that the working face remains small so
that it is more easily controlled throughout the day and more easily covered at the end of the day. Wind fence
panels had been deployed around the working face to help trap windblown litter within the operations area. All
of the panels had collected significant amounts of waste. Mr. Shelton stated that the fencing is cleared of waste
daily, as required. No unacceptable wastes were observed in the working face.
18. On March 12, 2020, the tipping and operating areas surrounding the working face appeared to contain clean
soil. However, the soil cover had been churned up by landfill equipment and trucks maneuvering as they
entered, discharged their loads, then exited the area. Exposed waste was evident throughout. At the time of the
June 23, 2020 inspection, this area was no longer active. However, the churned up and exposed waste observed
previously was still visible. Please ensure that the top of the inactive Phase 1-3 area is reshaped to
eliminate equipment ruts, that additional clean soil is applied to cover all exposed waste, and that
windblown litter is removed from the wind fence and equipment stored there. (See Status of Past Noted
Violations section of the report for additional information)
19. During the June 23, 2020 inspection, the working face had moved to the northern end of the new Phase 4. An
access roadway had been constructed leading into a tipping area that appeared to have been stabilized with
stone and compacted soil, thus providing a solid base on which trucks and equipment could maneuver safely.
The working face appeared to be somewhat larger than during the March 12, 2020 inspection. However, waste
appeared to be well compacted and no unacceptable materials were observed in the active disposal area. Two
tarps were staged in the operations area in preparation for covering the waste at the end of the day.
20. The following facility operations are located atop closed landfill units: white goods and scrap metal collection;
wood waste collection and processing; scrap tire collection; inert debris collection; convenience center;
residential recycling drop-off, electronics collection; and, container storage.
21. The convenience area, recycling drop-off, electronics collection area and container storage area are all located
Page 8 of 11

NORTH CAROLINAD_E Q��
OepeNn.nf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
on top of closed Area I and were found to be clean and well -maintained. The convenience area is manned
during operating hours, and windblown litter is retrieved by facility staff as it occurs. Both the convenience area
and the electronics collection area were neat and well -organized on March 12, 2020 and on June 23, 2020.
22. The scrap tire, wood waste, white goods, scrap metal and inert debris collection and operations areas are all
located on top of closed landfill Area IV.
23. On March 12, 2020, the wood waste area was found to contain a small pile of unprocessed brush and clean
wood, along with a small pile of ground wood waste. Mr. Shelton stated that the grinding contractor had
recently completed work, and that landfill staff had regraded and seeded the landfill cap to generate some
vegetative cover over the closed disposal area. The large stockpile of metal pipe that had been observed in the
wood waste area during the previous inspection on October 22, 2019 had been removed as requested.
24. No unacceptable materials were noted in the wood waste pile on June 23, 2020, and the area appeared to be neat
and well -managed when observed from the roadway.
25. At the time of the March 12, 2020 inspection, a pile estimated to contain at least 4,000 scrap tires was observed
on the ground covering the concrete pad above the trailer parking bays and spilling onto the gravel operating
area surrounding it. Ms. Heim advised facility staff that the scrap tire collection unit, as currently operated, did
not meet the requirements of 15A NCAC 13B .1107(2)(c), which states, in part, "Whole and partial scrap tires
capable of holding water shall be covered upon receipt with a water shedding material or disposed of,
processed, or removed from the site within 10 days of receipt." This issue had also been brought to the attention
of county staff during the previous comprehensive inspection on October 19, 2019.
26. During the March 12, 2020 inspection, technical assistance was provided to county staff with contacting the
county's scrap tire contractor to resolve the issue of insufficient trailer space and delayed trailer swap -outs.
Technical assistance was also provided to staff regarding options for managing the scrap tires while the surplus
remained and outside storage at the facility was necessary. During the June 23, 2020 inspection, an estimated
800 scrap tires were present onsite, and tires were observed being loaded from the cement pad into an open -top
trailer. Mr. Tate stated that any tires left onsite on the ground are covered daily with tarps, several of which
were visible on the pad next to the tire pile. He added that support from the scrap tire disposal contractor had
improved considerably.
27. During the March 12, 2020 inspection, Mr. Giachini requested records of the leachate volumes generated from
the underdrain located on the south corner of Phase 3. A log was provided listing the loads of leachate pumped
and hauled from the temporary tank where that leachate is stored. Mr. Giachini also requested records of the
inspection and monitoring of the entire leachate collection system. No documentation of periodic inspections
was available. It is recommended that a log of regular leachate collection system inspections be initiated
and maintained in the facility operating record.
Scrap tire pile located atop the gravel pad on Area IV of the closed landfill. (Photo taken by S. Heim 3112120)
Page 9 of 11

NORTH CAROLINAD_E Q��
OepeNnenf of Envlronmmbl 0w1�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Scrap tire pile significantly reduced in size with tarps available to cover the stockpile at the end of the operating day.
(Photo taken by S. Heim 612312020.)
A view of the new permanent leachate storage tank and pump system with electrical panel. (Photo taken by S. Heim 6123120)
The access road for the new leachate pump system was unnavigable by vehicle and badly eroded, resulting in concerns
about the future integrity of the pump system and electrical service panel. (Photo taken by S. Heim 6123120)
Page 10 of 11

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NORTH CAROLINA
Solid Waste Section
The limits of the current operations area in the northern end of the new cell has been clearly delineated with a built-
up ridge ofgravel and barrels in order to ensure the separation of leachate and storm water in Phase 4. (Photo taken
by S. Heim 6123120.)
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan
Heim
DN: cn=Susan Heim,
o=Solid Waste Section,
ou=Field Operations
Branch,
email=susan.heim@ncden
r.gov, c=US
Date: 2020.07.09 10:22:20
-04'00' Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: July 9, 2020 to Ronnie
X
Email
Hand delivery
US Mail
Certified No. [ ]
Tate via:
Copies: Jason Watkins, Field Operations Branch Head — Solid Waste Section
Deb Aja, Western District Supervisor — Solid Waste Section
Sherri Stanley, Permitting Branch Head — Solid Waste Section
Ervin Lane, Hydrogeologist — Solid Waste Section
Kathryn Jolly, Environmental Compliance Solid Waste Program Manager — Rockingham County
Edward Shelton, Landfill Supervisor — Rockingham County
Page 11 of 11