7803-CDLF-1997 _INSP_20210812

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Robeson
Closed MSWLF X HHW White goods X Incin T&P X FIRM PERMIT NO.: 7803-CDLF-1997
7803-MSWLF-1985 CDLF X Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: August 12, 2021 Date of Last Inspection: June 9, 2021
FACILITY NAME AND ADDRESS: Robeson County Landfill, 246 Landfill Rd., St. Paul’s, NC 28384 GPS COORDINATES: Lat: 34.79222 Long: -78.90828
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, NCDEQ, Solid Waste Section Ben Jackson, NCDEQ, Solid Waste Section Elizabeth Werner, NCDEQ, Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste Gene Walters, Robeson County Solid Waste Mousa Maimoun, Labella Hannu Kemppinen, Labella 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 December 29, 1997; Life of Site expires - December 29, 2057* 7803-CDLF-1997 Issued December 31, 1997; Life of Site expires - December 31, 2057*

PURPOSE OF SITE VISIT: Comprehensive Follow Up Inspection - Notice of Continuing Violation to follow.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 9
STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .0542 (l)(4) – RESOLVED 2. Permit Attachment 3, Part VII (78) – RESOLVED
Notice of Violation July 6, 2021
OBSERVED VIOLATIONS: 1. 15A NCAC 13B .0542 - (2) Surface water must not be impounded over or in waste. Upon inspection, water was found impounded over the CDLF landfill. Proper cover, grading, sloping of the CDLF should allow for shedding of storm water without erosion or impounding over waste. Refer to approved ops plan.

2. 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. During the last inspection, June 9, 2021, Section staff discovered a large amount of brick and block along west side on top of CDLF. When they inquired to landfill staff, they indicated it was clean block and was being stored for crushing to be used on roads. Section staff explained that nothing should be stored on top the CDLF and it
was either waste that needed cover or should be immediately removed. Upon inspection on August 12, 2021, the block waste was still present on top the CDLF and not covered or removed. Mr. Hammonds requested analytical documentation to show this block was indeed not a hazardous waste containing material. Mrs. Kristina provided
TCLP Report for the block on 8/17/2021. This waste should be removed from the CDLF immediately or should be covered as waste immediately and the area graded as necessary to prevent ponding of water.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 9

ADDITIONAL COMMENTS 1. Purpose of visit was to do a follow up inspection on the Robeson County Landfills and the recent Notices of
Violation Corrective Actions, as well as Pre Operation inspection for the new cells for the CDLF/MSWLF. Mr. Powell revisited the site on 9/15/2021 to look at the progress.
2. Several loads of mulch waste and some soil was staged onsite for mixing for ADC. Working face was small, other than clean block on west end.

3. New cell is constructed and seep repair area looks good.
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 4 of 9
4. Some edge of waste (EOW) markers were still difficult to see. This was an issue last visit and mentioned in
the previous inspection. Stay vigilant in maintaining ALL of these markers and mowing properly so inspectors and your staff can conduct proper inspections of the landfill toe and perimeter. Install additional EOW markers as necessary. One should be visible to the next. Some of the landfill was mowed well, but further mowing is needed.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 9
5. Along south side, exposed waste was visible. Side slopes should be graded to 3:1. Adequate sediment control measures consisting of vegetative cover, materials, structures, or devices must be utilized to prevent excessive onsite erosion of the C&DLF Unit. Once weather and conditions allow, be sure and repair according to permit. Cover, slope and establish vegetation, after covering is key for keeping erosion from reoccurring. 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 occurs and the soil around them is not eroding away. Look at SECP/Ops plan.
6. MW10 was locked and tagged properly. However, the concrete needs repair. Please fix properly. 7. Treatment and Processing Area didn’t have any unapproved waste that was visible. Stay vigilant with keeping unapproved waste from returning. Waste was very close to being in water. This location may need to be changed or built up with soil due to ponding water. Discuss with Consultant/Engineer and Section permitting engineer Ben Jackson on options to proceed.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 9
8. Three trailers for storing and hauling tires were almost full. The county receives a large amount of tires daily. Recommend you contact tire disposal facility for additional trailers or increase removal frequency to eliminate excess tires being stored on the ground for extended periods of time.
9. White goods and scrap metal storing area has slightly improved. It will take time to change the mentality of the dumpers at the LF to a new way of doing things, but stay vigilant with requiring the changes necessary to keep it
neat and orderly and to remain in compliance. Roll off containers are being used and concrete pad as well. Keep WG’s stored upright.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 9
10. Mobile Home staging and deconstruction area had only one home, dated 7/22/2021. Options were discussed onsite about changes to permit/ops plan for allowing more flexibility to Robeson County in deconstructing them to meet rule and permit requirements. County staff are considering demolishing the MH’s themselves and scrapping the metal. Mr. Jackson requested that county staff put together a proposed plan and submit to him. An amendment may be required for your permit. Any permit issues or problems or operation alterations that Robeson County may wish to change should be directed to Benjamin Jackson. Discuss mobile home deconstructions requirements and options with Mr. Jackson. Any changes need to be approved before they can take place. Permits and operation plans may need to be amended. Contact Information for the Section permitting engineer, Benjamin Jackson – [e-mail] / 919 -707 – 8234 office.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 9
11. Windblown and exposed waste were still visible on top the CDLF. Please cover and grade when weather allows. If these areas, “…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.” 12. Broken equipment should be removed and not stored on the CDLF.
13. Several of the issues observed during this inspection have been observed during previous inspections and violations cited. Section staff have worked with Robeson County staff and allowed time for addressing these issues and they have only worsened or have not been addressed sufficiently. Facility staff indicated that the difficulty in hiring and maintaining adequate staff are still ongoing issues and have contributed to the non-compliant conditions of the landfill. Staff issues aside, it is Robeson Counties responsibility to operate the landfills in accordance with the rules. Failure to bring the site into compliance may result in enforcement actions up to and including fines, or additional requirements for the facility. The County should consider all options including if necessary, contracting out the operation of this site or possibly modifying the hours of operation until
staffing and equipment are sufficient to maintain compliance. 15A NCAC 13B .0534 (2)(I) Proper Operation and Maintenance. The permittee must 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 the permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of the permit.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 9
CDLF Application/Operations Plan dated March 3, 2017, Section 3.1 (page 57 of 519) – It is stated, in association with Table 2 showing equipment at LF, “Equipment Requirements: The following equipment is used at the landfill. In general, the type and number of pieces of equipment listed here is expected to be suitable for handling the anticipated waste stream for the duration of C&D Landfill Expansion operations. Equipment needs will be reviewed annually, and additional equipment will be purchased or leased as needed. New equipment will be phased in as older equipment is retired.” 14. Additional grading or 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. A lot of the soil that is used for cover, had washed down all the way to the bottom of the landfill in the perimeter storm water ditch/swale. Exposed soil shall have vegetation established, and that should be good perennial grasses. Seeding and mulching of soil cover in a timely manner may assist in reducing some of the erosion issues at this facility. 15. Mr. Powell revisited the CDLF on 9/15/2021 to check on progress. Much has been covered and seeded, although, much more is needed especially along the south west. Trash was visible near and in ditches along SW side of CDLF. It is either windblown and should be picked up and removed to working face so
it can be covered, or it is exposed waste and should be properly covered in place. Be sure to keep all waste inside EOW. Mulch was staged on top to mix with soil for cover. Most of the top was covered well, and there was a small working face. Previous block that was staged has been covered. White goods area was more orderly. 16. 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. 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: 9/20/2021 X Email Hand delivery US Mail Certified No. [ _]
Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Benjamin Jackson, Engineering Project Manager – Solid Waste Section Elizabeth Werner, Hydrogeologist – 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