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HomeMy WebLinkAbout7904_INSP_20170705FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 9 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: 06/27/2017 and 07/05/2017 Date of Last Inspection: 05/23/2017 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: Kathryn Jolly, Environmental Compliance Solid Waste Program Manager Telephone: 336-941-7175 Email address: kjolly@co.rockingham.nc.us FACILITY CONTACT ADDRESS: P. O. Box 132 Wentworth, NC 27375 PARTICIPANTS: Martie Neugent, Landfill Supervisor – Rockingham County (June 27, 2017 only) Joe Ryder, Site Coordinator – Joyce Engineering (July 5, 2017 only) 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. The working face was observed at 7:00 am on June 27, 2017, prior to the landfill’s scheduled opening at 8:00 am. No cover (soil or tarp) was observed in the area of the working face. The exposed FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 9 waste covered a large area, and had also spilled out onto the access roadway. Two landfill staff were onsite, and one compactor was running over the current working face. Mr. Neugent stated that he had been told by his staff that the working face had been tarped and fully covered the previous day after closing time. The previous working face area, located to the southeast of the current working face, was also observed to have exposed waste and inadequate soil cover, as were other locations in the surrounding area. At a meeting on June 9, 2017, the county stated that a contractor would be hired to assist landfill staff with hauling dirt and spreading soil cover over the exposed waste. On June 27, 2017, the contractor was not observed at the facility. Mr. Neugent stated that the contractor needed to rent equipment and was currently working to acquire two large dump trucks that would enable him to continue his operations at the facility. 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. On July 5, 2017 at approximately 4:00 pm, the working face was observed and found to be much more compact than during previous inspections. The working face was situated in a bowl, with a tipping area adequate to allow vehicles to maneuver safely, and landfill equipment staged in the operational area surrounding it. Waste was moved into the working face and compacted as it was dumped. Landfill staff, with assistance from the contractor, began covering the working face at 4:30 pm. A tarp was applied to the working face and some soil was piled at the edge of the tarp adjacent to the tarpo-matic roller. Uncovered waste was visible framing the area immediately outside the tarp. Equipment operators applied some soil to the area above/behind the working face to try to cover some of the exposed waste on the rear slope. However, operational areas on both sides and above the working face were observed to be lacking the 6” of earthen material that constitutes adequate daily cover. 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. Close-up view of working face with tarp in place. Note areas of uncovered waste surrounding the tarp and in the operating area around the working face. (Photo taken 7/5/17 at 5:15 pm by S. Heim) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 9 View of the southeastern end of the working face from the north. Note exposed waste on the slope and windblown trash accumulating on the access roadway in this area. (Photo taken 6/27/17 by S. Heim) A wider view of working face and surrounding operating area. (Photo taken by S. Heim on 7/5/17) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 9 Area of side slope directly southeast of the current working face with exposed waste, inadequate cover and windblown trash. (Photo taken 6/27/17 by S. Heim) Same view of the area of side slope directly southeast of the current working face with exposed waste, inadequate cover and windblown trash. (Photo taken 7/5/17 by S. Heim) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 9 2. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(a) cited for failing to prevent silt from leaving the MSWLF facility. In some areas, new vegetative cover was observed on the slopes. However, rain had again caused damage to the slopes since the previous inspection on May 23, 2017. Erosion and sedimentation were observed in areas of the active landfill on both June 27 and July 5, 2017. The ditch line at the toe of the landfill was full of sediment and debris in most places. Some drains in the ditch line were buried under mud, and accumulation of sediment along the side of the access roadway was still evident throughout the facility. One portion of the ditch was observed to have been dug out, and the access roadway adjacent to it scraped of mud and debris. 3. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .1626(7)(b) cited for failing to prevent on-site erosion. On June 27, 2017, there was little evidence of slope repairs, and no work was taking place that day, due to the aforementioned equipment issues being experienced by the contractor. However, significant progress was observed on July 5, 2017. Mr. Ryder stated that a 5-acre area surrounding the current working face had been scheduled for hydro-seeding the week of July 10, 2017. 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. 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. Some of the landfill slopes were not stable enough to sustain the newly sprouted vegetative cover through the rain events that had occurred since the previous inspection on May 23, 2017; other areas were observed to be greening; and, bare areas were still visible where the slopes had continued to erode. This was especially true in the lower levels, where large rills had opened to expose waste. Additional corrective measures are needed to stabilize slopes and slow surface water runoff. 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. 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. It appeared that the size of the wood waste stockpile has continued to increase since the previous inspection on May 23, 2017, and no fire lanes been added. While grinding operations appeared to be in progress, only a small amount of waste had been processed. Mr. Neugent explained that the grinding company had stopped work due to equipment problems. Please note that failure to complete these corrective measures may result in additional tiered enforcement action. LEFT: Sediment fills the drainage ditch at the toe of the landfill and spills onto the access roadway. (Photo taken 6/27/17 by S. Heim) RIGHT: Slope repairs in progress. (Photo taken by S. Heim 7/5/17) FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 9 6. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0203(d) cited for accepting waste that the facility is not permitted to receive. During the previous inspection on April 27, 2017, a few pieces of painted wood, painted wood pallets and engineered wood were observed in the unprocessed wood waste stockpile. During this inspection, large pieces of plywood and fiberboard were again observed on the pile. Compliance cannot be demonstrated until the existing wood waste pile containing the unacceptable material is removed and disposed of properly. On July 5, 2017, a wooden pallet was observed in the pile of waste being pushed into the working face. I motioned to an equipment operator and, after he was safely stopped, pointed out the pallet. The operator was unaware that wood pallets are not acceptable waste; however, he removed the pallet from the working face and set it to the side. Ensure that landfill staff are trained to know and recognize wastes that are banned from landfill disposal, and that procedures are in place to remove and segregate unacceptable materials for proper disposal at a facility 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. A great deal of progress had been made throughout the facility where inmate crews and temporary staff had been used to collect windblown waste. However, during this inspection, windblown trash was observed along the access roadway directly across from the working face and in the vegetation on the slope adjoining the roadway. 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. On June 27, 2017, all but one of the leachate seeps and breakouts observed during the previous inspection on May 23, 2017 had been repaired. However, several new seeps were observed on June 27, 2017. Mr. Neugent stated that he would inspect the slopes and make necessary repairs immediately. On July 5, 2017, all previously identified leachate seeps appeared to have been repaired and covered, however Mr. Ryder was not able to confirm that fact. 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. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 9 OBSERVED VIOLATIONS: No additional violations were observed during this inspection. ADDITIONAL COMMENTS 1. An initial corrective action plan was submitted to the Solid Waste Section by Joyce Engineering on May 31, 2017. As a result of a meeting with Solid Waste Section staff on June 9, 2017, a revised corrective action plan, dated June 22, 2017, was submitted. 2. Current landfill operations were observed to be taking place in the Phase 3 Vertical Expansion. 3. On June 27, 2017, the working face of the landfill was inspected and found to be spread out, and inadequate cover was observed in the surrounding areas. However, on July 5, 2017, the working face was observed to be compact and was being maintained at a size designed to be covered by one of the facility’s tarps. See the Status of Past Noted Violations section of this report for additional information. 4. Grinding equipment was observed to be staged in the wood waste collection area, and a small pile of processed material was evident. However, Mr. Neugent stated that they’ve had equipment problems and were awaiting repair parts that would enable them to continue. See the Status of Past Noted Violations section of this report for additional information. 5. Plywood sheets and other engineered lumber were visible throughout the unprocessed wood waste pile, which had again increased in size since the May 23, 2017 inspection. See the Status of Past Noted Violations section of this report for additional information. 6. Windblown trash was observed to be profuse along the access roadway leading to the working face. See the Status of Past Noted Violations section of this report for additional information. 7. The inert debris stockpile had increased in size and included a large pile of used asphalt. No unacceptable waste was observed in the inert debris storage pile. 8. White goods were neatly staged on the concrete pad adjacent to the inert debris storage area. Units containing CFCs had been stored separately and upright so that gas lines would remain intact until evacuated. 9. The scrap tire collection trailer was empty on June 27, 2017, and no scrap tires were observed on the ground at the facility. 10. The area that had been the working face at the time of the April 27, 2017 inspection, located at the edge of the liner at the northwest corner of the perimeter road and working face access, had been repaired, regraded and covered with soil in preparation for hydro-seeding. (See photo on next page.) 11. Much of the road repaving project had been completed at the facility. Repairs to the area of roadway that had been undermined by runoff were observed to be underway. (See photo on next page.) 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 8 of 9 View of the area located at the northwest corner of the perimeter roadway and the working face access. Regrading and slope repairs complete, adequate cover applied. This area is part of the 5 acres scheduled to be hydro-seeded during the week of July 10, 2017. View of the section of perimeter roadway that had been undermined by surface water runoff with repairs in progress. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 9 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: July 14, 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