7803-MSWLF-1997_INSP_20210609

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: Robeson
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 7803-MSWLF-1997
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: June 9, 2021 Date of Last Inspection: January 6, 2021
FACILITY NAME AND ADDRESS: Robeson County Landfill 246 Landfill Rd., St. Paul’s, NC 28384 GPS COORDINATES: Lat: 34.792527 Long: -78.911066 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 Amanda Thompson, NC DEQ, Solid Waste Section
Kristina Locklear-Cummings, Robeson County Solid Waste Gene Walters, Robeson County Solid Waste
STATUS OF PERMIT: PERMIT TO CONSTRUCT - 7803-MSWLF-1997 – ROBESON COUNTY LANDFILL PHASE 5, PHASE 6 7803-CDLF-1997 – ROBSEON COUNTY CDLF, C&D LANDFILL EXPANSION
PERMIT TO OPERATE - 7803-MSWLF-1997 – ROBESON COUNTY LANDFILL PHASE 2, PHASE 3, PHASE 4 7803-CDLF-1997, ROBESON COUNTY CDLF – OVER CLOSED LANDFILL 7803-MSWLF-1985
7803-MSWLF-1997 Issued February 4, 2021; Life of Site expires - December 29, 2057*
7803-CDLF-1997 Issued February 4, 2021; Life of Site expires - December 31, 2057* PURPOSE OF SITE VISIT: Comprehensive Inspection – Notice of Violation to follow.
STATUS OF PAST NOTED VIOLATIONS: NA

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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OBSERVED VIOLATIONS:
1. 15A NCAC 13B .1626 (2) (a) – Except as provided in Sub-Item (b) of this Item, 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.
At the time of the inspection on June 9, 2021, large areas of exposed waste were observed sporadically along the top of the landfill, along beside the haul road, of the MSWLF at the time of this inspection. All exposed waste must be covered in accordance to the rules at the end of each working day and should be logged daily according to permit/rule. Staffing limitations and equipment breakdowns were discussed as contributing factors, but these issues must be addressed and maintained moving forward. Working face was too large to cover, in addition to this exposed waste, by end of the day. This was discussed before inspectors left and agreed upon. The operator had staged soil near the working face and intended on using two tarps for cover as well, this did not appear to be enough to cover the exposed waste. Cover issues have been addressed in prior inspections and appears to be an ongoing problem at this facility.

2. 15A NCAC 13B .1626 (11) (c) – Methods such as fencing and diking shall be provided within the area to confine solid waste subject to be blown by the wind. 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.
At the time of this inspection, windblown litter was observed along the east side slope and road to top of working face. Windblown litter should be picked up at the conclusion of each day and returned to the working face. Staffing limitations were discussed but these issues must be addressed and maintained moving forward. Some trash bags were present from staff doing a small amount of windblown pick up.
View is ~ east. Windblown and exposed waste visible on east side of MSWLF from office and parking lot.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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3. 15A NCAC 13B .1626 (8)(d) - Leachate shall be contained within a lined disposal cell or leachate collection and storage system. All leachate shall be treated, as required by the receiving facility, prior to discharge. An NPDES permit may be required prior to the discharge of leachate to surface waters, as provided by 40 CFR Parts 258.26 and 258.27.
At the time of this inspection, Section staff discovered a large, impounded area of leachate outside of the edge
of waste (EOW), right beside bottom of access road to working face of MSWLF and outside of the leachate collection system. This is on east side of LF but south side of the access road, within the perimeter storm water ditch. It was very easily discovered by inspectors riding up roadway to MSW working face. During the inspection of this area, it was observed, that a lot of soil had eroded away from that side of the road and exposed waste. This was visible for a good distance from the area where the leachate was impounded. It is likely that LF staff could see the area where the leachate was impounded and exposed waste along the access roadway every trip to and from the working face of MSW. Additional site training for staff may be needed so that staff is aware of what is unacceptable in operations plan/permit in order to respond quickly to areas of noncompliance. Exposed waste should be covered and leachate removed along with surrounding soil and replaced with clean soil. Clean all trash out of ditches. Follow sampling plan and leachate release guidance in permit/operations plan. County staff began pumping leachate into 18 wheeler hauler tank soon after Section staff alerted them. The County needs to document all corrective actions on this and other
issues. This area of EOW needs markers installed and shrubs removed.
View is ~ south, along MSW access road to working face. Exposed waste is visible. This is top of the area where
leachate and runoff started and flowed downhill.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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View is ~ northwest. Shows, right beside access road to working face, ponded leachate outside EOW, and exposed
waste.
4. General Statute § 130A-309.10. (f) Prohibited acts relating to packaging; coded labeling of plastic containers required; disposal of certain solid wastes in landfills or by incineration prohibited. (7) - Whole scrap tires, as provided in G.S. 130A-309.58(b). The prohibition on disposal of whole scrap tires in landfills applies to all whole pneumatic rubber coverings, but does not apply to whole solid rubber coverings.
At the time of this inspection, Section staff observed multiple scrap tires in and around the working face of the MSWLF. Remove and dispose of properly. Better screening should be done, both at scale house and working face and properly documented. All employees should know what items are not allowed to be disposed at LF. This will assist in keeping TVs, tires, painted pallets etc. from making it into landfill.
5. General Statute § 130A-309.10. (f) Prohibited acts relating to packaging; coded labeling of plastic containers required; disposal of certain solid wastes in landfills or by incineration prohibited. (12) - Wooden pallets, except that wooden pallets may be disposed of in a landfill that is permitted to only accept construction and demolition debris.
At the time of this inspection, Section staff discovered multiple painted wooden pallets in the MSWLF working face. Before inspectors could inform County, the pallets were crushed and pushed into other trash on MSWLF
working face.

6. General Statute § 130A-309.10. (f) Prohibited acts relating to packaging; coded labeling of plastic containers required; disposal of certain solid wastes in landfills or by incineration prohibited. (15) - Discarded televisions, as defined in G.S. 130A-309.131.
At the time of this inspection, Section staff discovered multiple Cathode Ray Tube Televisions on the MSWLF working face. Before inspectors could inform County, they were crushed and pushed into other trash on
MSWLF working face. Better screening should be done, both at scale house and working face and
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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properly . All employees should know what items are not allowed to be disposed at LF. This will keep TVs, tires, painted pallets etc. from making it into landfill.

View is ~southeast. Exposed waste with one of the tires found on MSW with office in background.

Cathode Ray Tube TV’s, several painted pallets visible at MSW working face. Before staff could alert County SW Directors, these were crushed and pushed into working face.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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ADDITIONAL COMMENTS 1. Purpose of visit was to do a comprehensive inspection on the Robeson County Landfills. Amanda Thompson and David Powell with the Section were inspecting onsite. Inspectors were also following up on Mr. Powell’s last
visit, 1/6/2021, when recent rainfall and high traffic going up to working face kept inspector from visiting working face. Access roads should be of all-weather construction and maintained in good condition.
2. Inspectors drove around entire LF along bottom and top, getting out periodically and walking to inspect compliance issues and hard to see areas of the LF. While driving up to the working face, inspectors observed a large amount of leachate impounded beside the access road within the perimeter ditch. Once the leachate was being addressed by site staff, inspectors rode up to and around the working face to continue the inspection of the facility while staying out of the way of the working equipment and trucks. 3. Operations are currently still in Phase 4 on MSWLF. Cells for Phase 5 and 6 are constructed. Erosion and storm water from active working face and downslopes of other inactive cells are washing on to the liner of newly constructed Cells. The erosion and storm water issues should be addressed quickly to protect new cell liner integrity.

View is ~ SE. Shows Phase 5 and 6, Phase 4 in background.

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 7 of 13
4. At the time of this inspection, inspectors observed trash bags reportedly from windblown waste pickup. This is good but the exposed waste/windblown issues at the MSWLF are going to require a lot of covering with soil and pick up what cannot be covered. The entire top, and side slops along top need to be covered, vegetated if not being used and any windblown collected and returned to the working face. Discussions onsite were about using mulch from other sites or mulching LCID waste and using for erosion control or ADC mixed with soil 50/50 to cover. 15A NCAC 13B .1626 (2) (a) Except as provided in Sub-Item (b) of this Item, 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. 15A NCAC 13B .1626 (2) (c) - Areas which will not have additional wastes placed on them for 12 months or more, but where final termination of disposal operations has not occurred, shall be covered with a minimum of one foot of intermediate cover.

View from parking lot of MSWLF east side and access road. 5. At the time of this inspection, seeps were observed on east side of MSWLF, and visible from office parking lot,
along with excessive amounts of windblown litter and exposed waste. Address seeps here and other areas where they are visibly occurring as soon as they are observed. Establish vegetation and add erosion control structures as needed, reference approved operations plan and SECP. Additional seeps were noted to be on the east and northeast corners of MSWLF. The entire perimeter of the landfill should be inspected for additional areas in need of repair.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Leachate seeps, east side.

Windblown and exposed waste, east side. 6. MW26, MMW15, MW21 were locked, and tagged properly. However, MW21 can be easily moved by hand and
is holding on only by the well pipe. This should be addressed right away and repaired in accordance with 15A NCAC SUBCHAPTER 02C. Area around the wells and sampling points should be mowed regularly. Be sure and document any actions. Permit Attachment 3, Part I, (20) (e). - Documentation of well completion, development details, repair, abandonment, and other activities associated with each groundwater and landfill gas monitoring well must be maintained in the facility operating record.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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MW21 need repair. 7. At the time of this inspection, shrubs and large weeds were growing all around the MSWLF and should be cut. More frequent mowing is necessary to manage the woody and lush vegetation. Having good thick grass/vegetation is preferred over low cut grass. This will need to be done in addition to new vegetation to maintain the LF slopes and compliance with the rules. Careful attention should be given around wells to ensure no damage and the soil around them is not eroding away. Section staff should be able to see EOW markers at all times while the MSWLF still has the vegetative cover it needs to protect from erosion.
8. At the time of this inspection, Inspectors observed that the working face was quite large. Some soil was staged for cover, along with tarps, atop the MSWLF, but did not appear to be enough to cover all of the working face waste and the other areas of exposed waste. The MSWLF should keep a smaller working face to be able to
address the covering that is needed and to keep waste compacted. 15A NCAC 13B .1626 (a) - MSWLF units shall restrict solid waste into the smallest area feasible. (b) - Solid waste shall be compacted as densely as practical into cells. 9. Erosion rills were also visible around top of MSWLF from recent rainfall. A severe erosion rill from working face, down slope from Phase 4 into newly constructed Phase 5(refer above to photo in #2 in Additional Comments). Exposed waste could be seen in the rill. Please cover and slope all areas accordingly when
conditions allow. Address erosion, by adding soil, structures, vegetation, etc. Again look at SECP and Ops
plan.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Looking at working face on Phase 4 on right and Phase 5 on left. Severe erosion rill down slope can be seen.

Looking west on previous phases. Exposed waste and no vegetation on area not being used. 10. Records reviewed, were sent via email after inspection, consisted of permit, operations plan, certified operator certifications, a few random waste screening reports, white good and scrap metal 2021 hauling docs, Methane Monitoring Well readings for 3/13/21 and 5/27/21; Leachate Analysis lab reports and hauling records for 1/2021,
2/2021, 3/2021, and 4/2021; Jan. 2021 and April 2021 monthly waste summary reports. Certified Operators: Angela Strickland Expires 6/19/2021; Craig Hunt expires 6/19/2021; Dennis Currie expires 10/1/2021; Josef Ivey expires 6/19/2021.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Discussed documenting unaccepted loads in waste screening records. This documents you are doing your part in keeping these items from going into wrong place. Hunt Environmental and Associates, Lumberton NC does groundwater sampling. April 2021 Water Quality Monitoring Report was also sent. 11. Before leaving, Section staff sat down with Ms. Kristina and Mr. Gene to discuss their findings at all facilities. During that time, leachate was being recovered, additional staff were being contacted for responding to issues discovered during inspection. Staff were informed that the following day parts would arrive and equipment
would be repaired. Mr. Gene informed Mr. Powell on 6/22/2021 that the compactor was back up and working again. The following day, contracted dump trucks and operators were supposed to arrive and the County was attempting to find additional resources. Section staff were also informed that the County would begin covering
the exposed wastes at the MSW and leachate seep repair immediately. Windblown management, using inmates or other staff, was mentioned during the discussion of staffing limitations. Mr. Gene discussed upcoming partial closure of MSWLF phase 2, 3 and 4 coming soon he hopes. Contact permitting for guidance as necessary.
12. Any permit issues or problems or operation alterations that Robeson County may wish to change should be directed to Benjamin Jackson. Any changes need to be approved before they can take place. Contact Information for Robeson County Section Engineer Project Manager Benjamin Jackson – [e-mail] / 919 -707 – 8234 office. 13. Although the County may have issues with recruiting new staff or issues with current staff, it is Robeson Counties responsibility to operate the landfills in accordance with the rules or accept further compliance action. This could be in the form of fines, or additional requirements, which carry additional costs, should the violations continue to reoccur or go unresolved. If the county doesn’t have the equipment or the staff to operate the landfill according to rules and permit conditions, then contracted staff and equipment may be needed or changes in operation may need to be considered. 15A NCAC 13B .1604 (2)(I) Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance include effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality control procedures. This provision requires the operation of back-up or auxiliary
facilities or similar systems only when necessary, to achieve compliance with conditions of the permit. 14. There will need to be multiple step approach to addressing these issues. Leachate seeps and proper soil cover should be addressed immediately to counter other leachate issues and from adding to excess windblown waste. Follow Leachate Release Sampling and Analysis Guidance document. additional grading and erosion control measures may need to be added to the areas where there are reoccurring erosion issues. Refer to approved plans and or discuss with Engineers for recommendations on correcting these issues. Areas not being used shall have vegetation established, and that should be good perennial grasses. A lot of the soil that was used for cover, had eroded down all the way to the bottom of the landfill into the perimeter storm water ditch. Check the entire perimeter of LF and be sure all EOW markers are in place correctly. Cut shrubs and woody revegetation growing on and around the LF.
15. 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 to follow up on these corrective actions. Failure to meet the conditions for compliance may result in additional Compliance Actions.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Please submit a Sampling Plan for Section approval prior to sampling. The proposed plan shall be submitted in electronic format sent via email and meet the following requirements: 1. Include a map/aerial photo depicting area of impact and proposed sampling locations; 2. Provide a description of the proposed sampling methodology; and
3. Describe proposed subsurface soil sampling and surface water sampling (if applicable) at specific locations, including background soil and upstream water locations, to evaluate the extent of the potential environmental impacts from the release(s) at the facility;
a. Subsurface soil samples shall be collected between one to two feet below ground surface; b. Discrete soil samples shall be collected. Composite samples will not be accepted; and c. All soil and surface water samples shall be analyzed by a NC certified laboratory for 40 CFR Part 258 Appendix I parameters (VOCs and Total Metals), total phosphorus, sulfate, nitrate, and pH.
After Section approval of the sampling plan, the plan shall be implemented within seven (7) days. Within 10 business days after receiving the analytical results from the laboratory, submit documentation regarding the sampling event which shall include the following: 1. A summary of the leachate release, actions taken to address the release, and the release assessment; 2. A map/aerial photo depicting the sampling locations; 3. A table of the surface water analytical results compared to the NCDWR Surface Water Quality Standards & Protective Values; 4. A table of the subsurface soil analytical results compared to the NCDEQ Preliminary Soil Remediation Goals (PSRGs). Both the Residential Health Based and the Protection of Groundwater PSRGs must be met; 5. The associated laboratory reports from the NC certified laboratory including the chain of custody and QA/QC results; 6. The sampling methodology, if different from the proposed plan; and 7. Conclusions and recommendation. Submit the results to Elizabeth Werner, Hydrogeologist, 1646 Mail Service Center, Raleigh, NC 27699-1646, [e-mail], 919-707-8253, Environmental Senior Specialist, [e-mail], 919-280-5135.

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: [phone] _ David Powell Environmental Senior Specialist Regional Representative
Sent on: 6/29/2021 X Email Hand delivery US Mail Certified No. [ _]

Copies: Jason Watkins, Field Operations Branch Head Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Benjamin Jackson, Engineering Project Manager – Solid Waste Section
Amanda Thompson, Environmental Senior Specialist – Solid Waste Section Chris Hollinger, Compliance Officer Elizabeth Werner, Hydrogeologist – Solid Waste Section
Kristina Locklear-Cummings, Robeson County Solid Waste Kellie Blue, County Manager, Robeson County