7803-CDLF-1997_NOV_20210706

July 6, 2021

CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7020 0090 0001 7206 9702

Gene Walters, Solid Waste Director
Robeson County,
246 Landfill Rd., St. Paul’s, NC 28384

SUBJECT: Notice of Violation Compliance Inspection Report
Robeson County CDLF
7803-CDLF-1997
Robeson County

Dear Mr. Gene Walters:
On June 9, 2021, Amanda Thompson and David Powell, representing the State of North Carolina, Division of
Waste Management Solid Waste Section (Section), inspected the above referenced facility for compliance with North Carolina solid waste statutes and rules. Gene Walters and Kristina Locklear-Cummings were present and
represented Robeson County Landfill during this inspection. The following violation(s) were noted:

A. 15A NCAC 13B .0542 (l)(4), Leachate must be contained on-site or treated prior to discharge. An NPDES
permit may be required prior to the discharge of leachate to surface waters.
At the time of the inspection, Section staff discovered a leachate release on the west side of CDLF.
Leachate was ponding from this seep into the newly constructed cell. Robeson County Kristina
Cummings arrived shortly after discovery by inspectors. Repairs began before inspectors left at end of day.

B. Permit issued February 4, 2021, Attachment 3, Part VII (78) - All mobile homes must be deconstructed within 45 days from acceptance into the deconstruction area. The date of receipt at the landfill
shall be posted on the mobile home or its frame.
At the time of the inspection, Section staff found 14 mobile homes still onsite and many were dated
beyond the 45 days’ time limit per the permit. Earliest date onsite was dated 1/7/2021. When
inspectors discussed this with Mr. Gene and Ms. Kristina, they informed inspectors that the contractor was coming the following week. They further explained they are having severe difficulty with this time
limit due to finding someone to demo them because of the housing market boom and limited
contractors willing to do this work.
C. 15A NCAC 13B .0542 (f)(1) Except as provided in Subparagraph (3) of this Paragraph, the owners and
operators of all C&DLF units must cover the solid waste with six inches of earthen material when the waste disposal area exceeds one-half acre and at least once weekly. Cover must be placed at more
frequent intervals if necessary to control disease vectors, fires, odors, blowing litter, and scavenging. A
notation of the date and time of the cover placement must be recorded in the operating record as
specified in Paragraph (n) of this Rule.
Robeson County Landfill Notice of Violation
Page 2 of 3
July 6, 2021

At the time of the inspection, Section staff determined the disposal area was larger than ½ acre and not receiving the proper cover. Exposed waste was visible on the north, south and on top of the CLDF
and smaller areas with erosion rills. When cover logs were later requested via email, it was determined
that there were no cover logs and County staff were unsure when they had stopped documenting and maintaining the cover logs.

Based upon the foregoing, Robeson County Landfill shall come into compliance within 30 days’ receipt of this Notice with all requirements of the regulations in 15A NCAC 13B .0542 (l)(4), .0542 (f)(1) and permit issued
February 4, 2021, Attachment 3, Part VII (7) by completing the following at the Robeson County Landfill:
A. Remove the leachate impacted soils and repair and regrade the slope on the west side of CDLF.

B. Inspect entire CDLF for additional seeps and repair accordingly.
C. All mobile homes should be deconstructed according to approved operations plan and permit. Any
changes to the permit conditions or operations plan must be submitted to permitting for approval.
D. Cover must be placed at more frequent intervals if necessary, to control disease vectors, fires, odors,
blowing litter, and scavenging. A notation of the date and time of the cover placement must be recorded in the operating record, maintained and available for inspection.

E. Areas which will not have additional wastes placed on them for three months or more, but where final termination of disposal operations has not occurred, must be covered and stabilized with vegetative ground
cover or other stabilizing material.
F. The block/brick cannot be stored on the landfill without prior approval from permitting and should be
disposed of in the landfill or removed to another location per permitting approval. Follow up with the
generator to determine if the block/brick waste may contain fiberglass or asbestos.

G. Ensure that approved erosion control structures where severe erosion has caused leachate or exposed
waste.
H. Tires should be removed to proper disposal site as required. Have them removed, before storage outside
of trailers is needed.
I. Clean up scrap metal and white goods area. Waste should be in a roll off or stored on concrete slab only.

J. Ensure that the landfill is being operated in accordance with permit and approved operations plan. Any
operational changes should be approved by permitting before they are implemented.
K. Notify David Powell, Environmental Senior Specialist of completion of corrective actions. A follow up
inspection will follow within about 30 days’ receipt of this NOV.
The violation(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.
Robeson County Landfill Notice of Violation
Page 3 of 3
July 6, 2021

Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct a follow-up inspection to verify that the operator has completed the requirements of this Notice of Violation.

If you have any questions, please contact me at (910) 433 - 3350 or e-mail [e-mail].
Sincerely,

David Powell Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
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