78_N1092_INSP_20210609

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 8
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: 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: 34.787792 Lat: -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 Amanda Thompson, NCDEQ, 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 7 acre permitted site. PURPOSE OF SITE VISIT: Comprehensive Inspection – NOV to Follow STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .0566 (3) – UNRESOLVED 2. 15A NCAC 13B .0566 (4) – UNRESOLVED (Rule before 2021)

Notice of Violation July 31, 2020

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 8
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .0566 (3) All waste shall be covered with no less than six inches of soil monthly, or when the working face reaches one acre in size, whichever occurs first. Any soils used for cover at the site shall meet unrestricted use standards for soils as defined in G.S. 130A-310.65.

At the time of this inspection, exposed waste was visible and appeared to far exceed one acre in size.
Cover should be applied per the rules.

2. 15A NCAC 13B .0566 (1) - The site shall only accept those solid wastes that it is permitted to receive.
At the time of this inspection, unapproved wastes were visible comingled with the vegetative wastes. Unapproved wastes such as furniture, plastics, household municipal bagged trash, cardboard, large,
corrugated plastic piping were visible. Soil cover that was added to cover waste and also repair a seep,
discovered during last inspection, has what appears to be comingled MSW waste. Remove all unapproved items and dispose at appropriate area of landfill. Soil with MSW waste should go to MSW landfill.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 8
Household bagged trash, plastic cardboard
MSW waste/soil mix.

3. 15A NCAC 13B .0566 (2) Solid waste in the landfill shall be compacted. Slopes shall not exceed a ratio of three horizontal to one vertical at any time.
15A NCAC 13B .0201 (c) states, “No solid waste management facility shall be established, operated, maintained, constructed, expanded, or modified without a valid permit issued by the Division for the specified type of activity. It is the responsibility of every owner or 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.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 8
At the time of the inspection of the NLCIDLF, vegetative wastes were allowed to be dumped over a large area across the 3-acre notification and outside of the approved EOW into roadway beyond
markers. Waste needs covering and proper sloping and should be done in as small and compact
cells. All done inside of the EOW and approved area. Sufficient EOW markers for knowing boundary for disposal and a dumper traffic control system should be implemented to control where waste is dumped.
EOW markers buried in waste along right side of waste in photo, waste outside of EOW and in roadway. Road now is diverted around waste.
4. 15A NCAC 13B .0566 (8) Surface water shall be diverted from the working face and shall not be impounded over waste.
15A NCAC 13B .0566 (9) Solid waste shall not be disposed of in water.
At the time of this inspection, water was observed impounded on and around NLICDLF and waste was observed in water. Wastes should be covered and LF sloped well to promote positive drainage of water away and prevent soaking and erosion, which may also lead to leachate issues. Areas not being used should have grass established. There should not be standing water on the NLCIDLF. No waste shall be disposed of in water.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 8
Water impounded over waste. Not sloped to shed storm water.

Waste in water and outside of EOW.

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 6 of 8
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 and last year’s NOV issues. 2. 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. 3. Ruts and standing water were observed on the access road and around the NLCIDLF. Access roads
shall be of all-weather construction and shall be maintained to allow access by vehicles
transporting waste, Department staff an fire-fighting vehicles. A couple Edge of Waste Markers (EOW) were visible, however, waste was observed outside the
existing EOW markers and in the roadway. The requirement for additional Edge of Waste
markers (EOW) was mentioned in last two inspections and still have not been installed. These
should be visible on at least the four corners of the original 2-acre notification and then the four corners of the one-acre extension. Proper installation of EOW markers and the presence of an attendant should aid in waste being managed within the limits of the approved area. EOW markers should be visible from one to the other. Some were obscured by waste along roadway
where it has been allowed to be dumped outside of EOW. Suggest tall white PVC pipes.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 8
4. During previous inspection, it was recommended that proper management including covering, sloping and grading should assist in reduction of leachate issues in the future. This is the importance of building the NLCIDLF correctly throughout its operation. This is needed even more so currently. Kristina, with Robeson County SW and a new attendant started cleaning up some of the unapproved wastes while inspectors were still onsite. Waste was also being pushed back inside EOW. These issues will only be fixed by being very proactive not reactive.
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. Recommend that County staff follow up on the status of the permit application.
6. 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 violations continue to reoccur or go unresolved. If the county doesn’t have the equipment or the staff to operate the landfill according to rule, then contracted staff and equipment may be needed or changes in operation, may need to be considered. 7. 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

Page 8 of 8
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 –Solid Waste Section Elizabeth Werner, Hydrogeologist – Solid Waste Section
Kristina Locklear-Cummings, Robeson County Solid Waste
Kellie Blue, County Manager, Robeson County