7803-MSWLF-1997_INSP_20211028

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: 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: 34.792527 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 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 Follow Up Inspection STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .1626 (2) (a) – UNRESOLVED (rule Pre September 2021 re-adoption) 2. 15A NCAC 13B .1626 (11) (c) – UNRESOLVED (rule Pre September 2021 re-adoption) 3. 15A NCAC 13B .1626 (8) (d) – 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 this visit was to do a follow up inspection on the Robeson County Landfills and the recent Notices of Violation Corrective Actions. After the August inspection, Mr. Jackson was considering only permitting a partial opening Cell 5 (Area 1) to assist with addressing the exposed waste and to help control further erosion. PTO has
not been issued yet and operations in the new cell cannot begin until PTO is issued from Section Permitting.
2. A letter from the Robeson County Solid Waste Department was received by Mr. Powell the morning of this inspection following up on progress made on corrective actions so far and, after speaking with Mr. Walters and Ms. Locklear-Cummings, it was understood to be requesting additional time to finish addressing onsite corrective actions. Forty-five days from when inspection is sent was agreed upon. That time frame would put corrective actions due around on December 27, 2021 Monday, next business day following Christmas, and to expect a follow up around that time. Of course inspectors with the Section can arrive at any time LF is open to check on progress. 3. Cover logs were also provided upon arrival for the LF’s onsite. MSWLF cover logs were available back to 6/24/2021, with covering of tarp daily and weekly soil covering indicated on the new forms now used by LF staff. Robeson County has been using a lot of 50/50 ADC and should be keeping records on that waste.
Permit Attachment 3, Part 1, (14) (c) - The permittee must maintain records for all solid waste materials accepted and used as ADC. The records must include: the date of receipt, weight of material, general description of the material, identity of the generator and transporter, and county of origin. Records must be made available to the Section upon request.
4. Mrs. Locklear-Cummings, Mr. Walters, and Mr. Powell drove around LF along bottom and top, getting out periodically and walking to inspect compliance issues and hard to see areas of the LF. Seeps have been repaired on east side near access road to working face. At the time of this inspection, the leachate cleanout that was open before was now closed. Windblown was much better with staff actively picking up windblown during inspection. Good job. 5. Mr. Walters indicated that further sampling is still needed at previous leachate ponding area between working face and leachate holding tank, on side of access road. Follow approved recent sampling plan/permit/Ops Plan. Water in photo below was recent storm water and shrubs along toe of slope and EOW were cut along with that side mowed. EOW markers and ditch cleanup are needed here, after samples are taken and remediation activity completed maintain storm water ditch and EOW. This should be done ASAP.
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
Rain water in ditch behind leachate tank from recent rain.
6. Operations are currently still in Phase 4 on MSWLF. Cells for Phase 5 and 6 are constructed. The seep and severally eroded area, where cells join inside corner, has been repaired, mostly. Soil cover has been added and
straw grass with seed to a large are that has been repaired. Looks good so far. Due to shape and contour it still allows for storm water to funnel into small area feeding to new cell. Keep an eye and maintain on this area. Mr. Walters is considering using new existing leachate collection system to capture all the leachate water and pump to holding tank.
Looking into new cell ~ West.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 8
Looking ~south on top MSWLF. 7. At the time of this inspection, it was observed that the working face was of appropriate size. Some soil and mulch was staged for cover, along with tarps. Working face was being covered with 50/50 mix ADC of soil and mulch. Mulch is mostly coming from Town of Fairmont YWN, ~ 6 loads a day, but some still comes from Wilkes Rd. Cumberland County periodically. Mr. Walters would like to finish the east side before moving over to new cell expansion once PTO is approved and received. Covering looks good around working face. Top of MSWLF has had much cover but needs more along with sloping to 3:1 adjustment when weather allows, including east
side where working face is located.
East side, access road to working face. 3:1 Sloping needed to be improved.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 8
8. Older cells still have some windblown and/or exposed waste. Either it needs to be covered or picked up and put into working face and covered appropriately. More cover, with seeding, has been added to older cells along west side. More is needed with proper sloping however to ensure 3:1 sloping. West and north side of older cells, boarding new cell, need increased erosion control. Much mowing on these cells has been accomplished but there is still more along north side and couple other areas.
Top of MSLWF looking onto older cells westward. 9. West side of MSWLF older cell, mowed, covered, sloped and grassed. Good job, just be sure and manage it until grass is well established or given approval for final closure covering.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 8
10. South side has had cover and seeding. Some rills were present from recent rain, be sure and replace soil, 3:1 slope, and continue establishing grass cover. Some mowing needed along toe of slope.
11. Windblown/exposed waste on east side was much better. Good job. Area needs mowing and ditch cleaned out.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 8
12. Previous inspections noted, “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.” This MW has been repaired and mowed around it so it is not hit in future by mowing equipment. Good job.
13. More frequent mowing was requested in previous inspections, and much has been done to mow around the MSLWF. Please continue to be vigilant in maintaining the mowing and inspecting side slopes for seeps, windblown etc.
SE side of MSWLF.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 8
14. Any permit issues, 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 Section Permitting Branch Engineer Benjamin Jackson – [e-mail] / 919 -707 – 8234 office. 15. 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. Repair current erosion control structures. 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. Check the entire perimeter of LF and be sure all EOW markers are in place correctly, add more were needed. Mow where necessary around the LF. Addition of cover is needed in some areas but remember 3:1 sloping on all LF’s here at Robeson County. Inspect all wells and cleanouts while checking for damage. Much work has been done to improve the landfills at Robeson County but more is still needed to reach full compliance. Corrective measures to bring this facility into compliance should be complete within 45 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: 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