78_N1092_INSP_20200714

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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UNIT TYPE:
Lined
MSWLF LCID X YW Transfer Compost SLAS COUNTY: Robeson
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: N1092
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE
Date of Site Inspection: July 14, 2020 Date of Last Inspection: July 10, 2020

FACILITY NAME AND ADDRESS: Robeson County Landfill 246 Landfill Rd.
St. Paul’s, NC 28384 GPS COORDINATES: N: 34.787792 W: -78.907991
FACILITY CONTACT NAME AND PHONE NUMBER:
Gene Walters, Solid Waste Director 910-865-3348 [e-mail] FACILITY CONTACT ADDRESS: PO Box 366 St. Paul’s, NC 28384

PARTICIPANTS: David Powell, NC DEQ, Solid Waste Section Andrew Hammonds, NC DEQ, Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste
Gene Walters, Robeson County Solid Waste STATUS OF PERMIT:
Notification July 2016 Recently requested to convert to a 10 acre permitted site.
PURPOSE OF SITE VISIT: Comprehensive Follow-up Inspection STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .0563 (1) (a) - UNRESOLVED 2. 15A NCAC 13B .0566 (2) – UNRESOLVED 3. 15A NCAC 13B .0563 (3) – UNRESOLVED 4. 15A NCAC 13B .0566 (3) – UNRESOLVED 5. 15A NCAC 13B .0566 (4) – UNRESOLVED 6. 15A NCAC 13B .0566 (11) – UNRESOLVED
OBSERVED VIOLATIONS:
A. 15A NCAC 13B .0201 (c), States that “No solid waste management facility shall be established,
operated, maintained, constructed, expanded, or modified without a currently valid permit issued by the Division for the specified type of disposal activity. It is the responsibility of every owner
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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and operator of a proposed solid waste management facility to apply for a permit for the facility.
The term "owner" shall include record owners of the land where the facility is located or proposed to be located and holders of any leasehold interest, however denominated, in any part of the land or structures where the facility is located or proposed to be located.”. At the time of this inspection, the waste onsite was beyond the previously approved less than 3 acre
limitations for the Notified LCID. A permit is required to operate a facility larger than 2 acres. The NLCID Facility had been approved for a total of Three (3) acres due to increased demand from recent hurricanes. Section staff used a laser range finder to measure the expanded area beyond the 2-acre
notification and determined it was approximately 1.7 acres in size, not the 1 acre as approved. Total NLCID LF size of approximately 3.7 acres. B. 15A NCAC 13B .0566 (2), States that “The facility shall only accept those solid wastes which it is permitted to receive.” Upon follow up inspection, Section staff noticed stockpiled waste on the 2 acre notified side, mostly
along road and EOW. After questioning Mr. Gene Walters, he informed Section staff onsite that it was his understanding it was Sand Blast media. It was requested for the County to provide analytical results to determine the material content and approval for disposal in the NLCID. Mr. Walters
received documentation and forwarded to Section Staff, on July 21, 2020, and the material was “Bottom Ash” provided by NC Renewable Power – Lumberton. Mr. Walters spoke to David Powell
with Section about removing the material to the Lined MSW. The material needs to be removed from
NLCID, careful for dust when transporting or moving material. Mr. Walters was informed to remove the waste from the NLCID and to dispose of the waste in the MSWLF and to follow in the Divisions
“APPROVED ALTERNATIVE DAILY COVER MATERIALS” May 16, 2019 Guidance. It is recommended not to be used on exterior slopes at this facility.

ADDITIONAL COMMENTS 1. NLCID had been approved for an additional One (1) acre of LF added to the Two (2) acre, total of Three (3) acres, notification on October 18, 2018 by the Section, due to increase demand from recent hurricanes.
2. Facility staff, since July 10, 2020 visit, have pushed waste East towards water and not removed unapproved. Please remove unapproved waste immediately before accepting any new waste to keep from complicating the comingling of unapproved waste. Please document the removal, suggest pictures of waste removed and providing to the Section Staff inspecting.
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.
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3. Please reference violations from July 10, 2020 that need corrective actions still. 4. County staff discussed with Section staff the need for additional staff to address operating issues that are
causing the Facility to fall behind with facility upkeep and were in the process of interviewing to fill vacant positions. Unapproved wastes could potentially be stopped from entering LF, before its disposed of in LF, if there were dedicated staff to monitoring and removing these wastes onsite. Discussed additional measures to educate their customers, similar to the safety measures of having a hard hat and a safety vest that’s already in practice here. 5. As a reminder, any changes to the facility or operations plan should be submitted to Section permitting for approval before they are enacted. County staff have requested a Permit for LCID. Permits and approved operations plans must be followed. Contact Information for Robeson County Section Engineer Project Manager Benjamin Jackson – [e-mail] / 919 -707 – 8234 office
6. Corrective measures to bring this facility into compliance should be complete within 30 days’ receipt of this inspection report. A follow up compliance inspection will be conducted by Solid Waste Section Staff within 30 days. Failure to meet the conditions for compliance may result in further Compliance Actions.
Please contact me if you have any questions or concerns regarding this inspection report. ________________________________________ Phone: [phone] _
David Powell Environmental Senior Specialist Regional Representative

Sent on: 7/30/2020 X Email Hand delivery US Mail Certified No. [ _]
Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Benjamin Jackson, Engineering Project Manager – Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste