83_N0656_INSP_20201218

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: Scotland
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: N0656
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: December 18, 2020 Date of Last Inspection: NA
FACILITY NAME AND ADDRESS: City of Laurinburg NLCID LF 503 Hall Street Laurinburg, NC 28352 GPS COORDINATES: Lat.: 34.765355 Long.: -79.448782 FACILITY CONTACT NAME AND PHONE NUMBER: Angie Foster General Services Supervisor 503 Hall Street
Laurinburg, NC 28352 [phone] [e-mail]
Harold Haywood General Services Director
[e-mail] FACILITY CONTACT ADDRESS: City of Laurinburg Waste Management 503 Hall Street Laurinburg, NC 28352 PARTICIPANTS: David Powell – Solid Waste Section STATUS OF PERMIT: Notified 2005 Pre Regulatory Landfill NONCD0000565
PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: NA NOTICE OF VIOLATION:
A. 15A NCAC 13B .0105 (a), States that “The solid waste collector shall be responsible for the collection and transportation of all solid waste to a solid waste management facility as defined in G.S. 130A-290 that is permitted by the Division.” You have collected and transported solid waste to a site that is not a permitted solid waste management facility
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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for this type of activity. B. 15A NCAC 13B .0105 (b), States that “The solid waste collector shall transport to a site or facility only those solid wastes that are allowed by facility permit.” You have collected and transported Construction and Demolition (C&D) solid waste, such as metal flanges, PVC
pipe, hoses and plastic, to a site that is not permitted to receive such waste. C. 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 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 2 acre limitations
for the Notified LCID landfill. A permit is required to operate a facility larger than 2 acres. D. 15A NCAC 13B .0566 (2), States that “The facility shall only accept those solid wastes which it is permitted to receive.” At the time of this inspection, Construction and Demolition (C&D) solid waste, such as metal flanges, PVC pipe,
tires, hoses and plastic, was observed dumped on this property outside the limits of the NLCID. These wastes are not approved for disposal in a Notified LCID landfill.
E. 15A NCAC 13B .0566 (3), States that “Solid waste shall be restricted to the smallest area feasible and compacted as densely as practical into cells.”
At the time of this inspection, it appeared that the entire NLCID was uncovered, which is beyond the 2 acre NLCID LF limits. F. 15A NCAC 13B .0566 (4), States that “Adequate soil cover shall be applied monthly, or when the active area reaches one acre in size, whichever occurs first.”
At the time of this inspection, exposed waste was visible and appeared to exceed one acre in size and had not been covered in the past 30 days because vegetation was observed growing up around some of the waste. G. 15A NCAC 13B .0566 (10), States that “Surface water shall be diverted from the working face and shall not be impounded over waste.”
At the time of this inspection water was found impounded over the NLCID LF waste in a few areas.

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

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ADDITIONAL COMMENTS
1. Upon arriving at the facility, the inspector visited the main office building. Mr. Powell gave a representative
inside a business card and he was informed that no one was left working and all had gone home. Mr. Powell indicated he would inspect anyway but would reach out to Angie Foster later.
2. There is a sign at the facility entrance showing the contact name and number for the facility.

3. The facility shall be adequately secured by means of gates, chains, berms, fences, etc. to prevent unauthorized access except when an operator is on duty. An attendant shall be on duty at all times while the landfill is open for public use to assure compliance with operational requirements and to prevent acceptance of unauthorized wastes.
There is a gate with a lock at the facility entrance. The facility has a gate, and was unlocked at the time of this inspection, and no attendant on site, after City of Laurinburg representative in the office indicated that there was no one left working due to upcoming holiday. 4. The facility is to be operated for the disposal of land clearing waste, inert debris, untreated wood and yard trash. During inspection, plastic, pipe, rope, tire, metal piping flanges and PVC pipe were visible across the NLCID LF. Unacceptable waste must be removed from the property and disposed of properly at a facility permitted to receive that waste type. Maintain all disposal tickets for review by Section staff.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Unapproved waste visible from road. (Tire) Unapproved waste.
Unapproved waste. (Pipe with rope through it.) Large metal flange surrounded by uncovered waste.
5. The total disposal area for the NLCIDLF is to remain under two acres in size. Based on Division of Waste Management records, there is a Pre Regulatory Landfill (NONCD0000565) under the foot print of this NLCIDLF. During inspection, inspector used laser range finder to determine the approximate width of waste footprint was ~ 145 yards along the roadway running West to East. Same method was used to determine an approximate length of waste footprint along roadway leaving site, that runs North to South, which was ~ 156
yards. This approximation was not conservative on the measurements. Waste was observed beyond the limits of the NLCIDLF. Stop accepting waste at this site. All waste beyond the limits of the NLCIDLF should be removed and disposed of properly.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Looking towards gate entrance. Waste exposed to left and right of picture view and behind. 6. The landfill has not been covered and properly maintained. It seems mostly yard trash, such as pine straw, is being disposed of in the NLCID LF, along with much unapproved waste. Waste was observed exposed with water impounded over waste. Cover the waste in accordance to the rules. Sloping and grading, 3:1 ratio, will be needed once waste is within less than 2-acre footprint. Once waste is inside the correct less than 2-acre foot print, 4 corner markers, Edge of Waste (EOW) markers, should be installed so operators and inspector know where the proper area of waste disposal is located. Recommend tall PVC pipe as the EOW markers, but something that will stay and is highly visible.
Lots of exposed waste and some unapproved waste. Lots of exposed waste and some unapproved waste.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Water impounded over waste. Water impounded over waste.
7. Just south of NLCIIDLF and across the access road, is some older vegetative material with lots of unapproved waste comingled with it. Plastic, tires, tarp material and other misc. materials were visible. After speaking with Angie Foster with the City, it seems this material is old material that has been stockpiled and never removed. It must be removed and the non-vegetative material must go to the appropriate landfill for disposal. Since this vegetative material is older, it may not have the composting energy to be able to meet the standard of 131 degree Fahrenheit for 3 consecutive days to be able to be distributed to the public. So, it is suggested to dispose of the material in the NLCIDLF or redistribute it slowly into the new material at yard waste notification. If you seek other options, you will need to speak with Donna Wilson in our Section. Either way, the material needs
to be clean vegetative material for disposal with the other materials going to the appropriate landfill and these areas cleaned up immediately.

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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8. The City is currently in discussions with Division of Air Quality on permitting an Air Curtain Incinerator to handle a certain amount of yard waste tonnage a year. Perhaps it would be easier for Laurinburg operations, as well as maintaining compliance, to permit one facility for your entire yard waste/trash needs. As it stands now,
with using the two YWN sites, also temporary disaster debris sites (TDDS), it will be difficult to keep storm debris separate during from normal yard waste during a disaster. Suggest looking at what land you have for potentially permitting all your needs under one facility and having the two TDDS for emergencies. With the new rule changes being approved a few days ago, Notified LCIDLFs must be permitted within 5 years or they will be not allowed to continue to receive waste. So this is inevitable to lose the NLCIDLF to either a permitted one or close. Permitting the current area is not an option due to the Pre regulatory landfill under and beside what you currently have onsite, and is also an issue for the current state of things with the NLCIDLF. This change also will likely change how many disposal areas can accept waste in about 5 years, possibly increasing
your volume during this transition. 9. It’s my understanding that a waiver can be signed by someone in the public and they can come and get the telephone poles across from the main office building. DWM is concerned that this material is being disposed of in this location because it is doesn’t appear that it is being removed. The “75% rule”, previously emailed, basically means 75 % of this solid waste should be removed within a calendar year. This does not seem to be
happening. So a periodic removal to the appropriate landfill, that takes creosote wood, salt treated timbers etc., would need to be done to ensure the removal of the waste cumulatively over time. In addition, I would caution you to allowing the poles to be chain sawed and cut up onsite, allowing the shavings to be left, which may eventually lead to a contaminated site over a period of time. I would suggest they clean up after cutting the chip waste or load “as is”. Some of these timbers may be very suitable for fencing posts, suggest advertising at local feed store and tractor supply. Of course those are suggestions, DWM just requires this material make it to
the proper place, in the proper timeframe, without contaminating the current site they are staged.
10. Rules will be sent via email: 15A NCAC 13B .0563 APPLICABILITY REQ. FOR LAND CLEARING/INERT
DEBRIS (LCID) LANDFILLS; 15A NCAC 13B .0564 SITING CRITERIA FOR LAND CLEARING AND INERT DEBRIS (LCID) LANDFILLS; 15A NCAC 13B .0566 OPERATIONAL REQ. FOR LAND CLEARING/INERT DEBRIS (LCID) LANDFILLS; 15A NCAC 13B .0562 BENEFICIAL FILL; 11. Corrective measures are necessary as result of this inspection. Measures to bring the site into compliance
should be completed within 30 days’ receipt of this report.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management
Solid Waste Section

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Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: 910 – 433 - 3350 _ David Powell Environmental Senior Specialist Regional Representative
Sent on:1/19/2020 X Email Hand delivery US Mail X Certified No. [7020 0090 0001 7206 9962] With NOV

Copies: Jason Watkins, Field Operations Branch Head - Solid Waste Section Drew Hammonds, Eastern District Supervisor - Solid Waste Section Jessica Montie, Compliance Officer - Solid Waste Section Ryan Channel, Unit Supervisor - Pre-Regulatory Landfill Program