7803-CDLF-1997 _INSP_20211028

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: October 28, 2021 Date of Last Inspection: August 12, 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 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 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 STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .0542 (l)(2) – RESOLVED (rule Pre September 2021 re-adoption) 2. 15A NCAC 13B .0542 (f)(1) – RESOLVED (rule Pre September 2021 re-adoption)
Notice of Violation July 6, 2021 Notice of Continuing Violation September 21, 2021
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 8
OBSERVED VIOLATIONS: NA

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. The previous inspection referenced an observed violation in error as “15A NCAC 13B .0542 - (2)” and it should have been “15A NCAC 13B .0542 – (l)(2).” These rules were readopted and the
reference changed when the rules were readopted September 16, 2021. Last inspections violations .0542 (f)(1) and .0542(l)(2) have been resolved. 2. More cover has been added on top of the CLDF, no water was impounded over waste and block waste on west side has been covered. All other violations have been corrected as well, except the mobile home (MH) deconstruction at time of inspection. Confirmation photos of them being deconstructed was sent via text to Mr. Powell on October 29, 2021. A resolution letter will follow this inspection. However, the County needs to address the obvious issues with meeting the required 45 days from receiving MH’s to deconstruct to keep the violation from reoccurring. This is an reoccurring problem. Last inspection it was stated, “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.
MH’s were demolished 10/29/2021.
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 3 of 8

CDLF top covered well and staged soil/mulch. Block properly covered in back to right.
3. Seep repair areas on west side of CDLF into new cell were repaired before and still look good. Erosion rills
have been addressed too. New cell is vegetated and still looks good. Be sure vegetation is established on this western slope to maintain soil cover. Good job.

Seep repaired areas still look good, erosion addressed well. New cell still in good shape.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 8
4. Perimeter of CDLF was more visible with recent mowing. Good job. Cover and seeding has been added to fix most erosion rills. EOW markers should be inspected periodically as well as mowing. 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. More are needed on MSWLF and CDLF. One should be visible to the next and extra is not a bad thing.
Looking west on south side.
North side slope.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 8
5. Along south side, exposed waste was previously visible. Side slopes needed better grading to meet 3:1 slope on last visit. Slopes were better this visit with addition of cover. Stay vigilant with maintain 3:1 slopes. Exposed waste/windblown had been removed and covered properly as well. Good job.
South side, cover added and seeded. Cover soil and mulch staged on top also visible. 6. Treatment and Processing Area didn’t have any unapproved waste that was visible. Previous visit the waste was very close to being in water. Area had been built up a bit and surrounding area had been graded to allow for better drainage. This location may need to be changed or built up more with soil. Discuss with Consultant/Engineer and Section permitting engineer Ben Jackson on options to proceed.
Pallet and clean wood area.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 8
7. Working face was small and had good cover. Several loads of mulch waste and some soil was staged onsite for mixing for ADC 50/50 mix. Mulch coming from Wilkes rd. Cumberland County and Town of Fairmont YWN. A tire was discovered on top CDLF and was removed immediately. Good job. Traffic cones being used to direct traffic and waste dumping. Weekly cover logs were provided for the CDLF since June 22, 2021. Please continue to be vigilante keeping these records. (Rule Ref. .0542 (f)(2)).
Working face in rear of photo and right. 8. White goods and scrap metal storing area was in fair condition. 9. Windblown and exposed waste were still visible on top the CDLF in a couple areas but has greatly improved. Please continue to 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.” 10. Broken equipment should be removed and not stored on the CDLF. County is actively trying to sell off older equipment not going to be fixed and /or used as spare parts. A new bulldozer has been received and is
helping with fixing and maintain areas of LF. Discussion onsite with Mr. Walters is once older equipment can be sold and removed then hopefully newer equipment can hopefully be bought to replace. 11. Before the inspection, potential contingency plans were discussed by Ms. Kristina, Mr. Gene and Mr. Powell. The County may want to consider having some type of plan or SOP, in which in certain situations, such as emergencies or certain compliance issues, having a preapproved plan to allow the
hiring of temporary staff, equipment, change of operations etc. that could be utilized during those times. This could give some flexibility and quickness to addressing compliance or emergency situations in a timely manner, of the counties choosing, but with a faster pre-approved plan. Situations such as the Mobile Home Deconstruction 45-day time limit could be better addressed if, for example, the normal contractor cannot be scheduled to demolish and equipment breakdowns with County equipment hinder itself from also demolishing in the approved time frame. Also, the County may look at addressing any operational changes by conversing with Benjamin Jackson on altering/modifying the Permit/Ops Plan to try and fix these or other issues onsite at the landfills.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 8
In addition, a letter from the Robeson County Solid Waste Department was received by Mr. Powell morning of this inspection following up on progress made on corrective actions and, after speaking with Mr. Walters and Ms. Locklear-Cummings, understood it to be requesting additional time to finish addressing onsite corrective actions. Forty-five days from when inspection is sent was agreed upon.
View of north side of CDLF from south side of MSWLF. Side slop mowed, erosion repaired and vegetated. 12. Additional grading or erosion control measures may be needed moving forward where there are reoccurring erosion issues. Refer to approved plans and or discuss with Engineers for recommendations on correcting these and the other issues mentioned in this inspection. 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. 13. Corrective measures are necessary as result of this inspection. A follow up inspection will be conducted by Solid Waste Section Staff in about 45 days from inspection sent date. Failure to meet the conditions for compliance may result in Compliance Actions.

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: 11/9/2021 X Email Hand delivery US Mail Certified No. [ _]

Copies: 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 Kristina Locklear-Cummings, Robeson County Solid Waste Kellie Blue, County Manager, Robeson County