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Home My WebLink About7803-MSWLF-1985 _INSP_20221206FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 13 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: December 6, 2022 Date of Last Inspection: January 27, 2022 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 harrell.walters@co.robeson.nc.us 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: March 17, 2022 - PERMIT TO CONSTRUCT - 7803-CDLF-1997 – ROBESON COUNTY CDLF, C&D LANDFILL EXPANSION December 13, 2022 - PERMIT TO OPERATE - 7803-CDLF-1997 – ROBESON COUNTY CDLF– OVER CLOSED LANDFILL 7803-MSWLF-1985 (this was reissued to address wording and some issues with 3/17/2022 PTC/PTO.) 7803-CDLF-1997 Issued December 31, 1997; Life of Site expires - December 31, 2057* PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: NA OBSERVED VIOLATIONS: NA 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 2 of 13 ADDITIONAL COMMENTS 1. Purpose of visit was to do a comprehensive inspection on the Robeson County Landfills. Facility is secured by gate/fence and road made of all-weather construction. An operator was onsite during inspection visit. 2. Signage needs to be updated to reflect new rules and permit. The signage needs to be updated for new permit conditions for other facilities as well. The main sign can be altered to fit all, but to minimize confusion it is suggested to add a sign at the entrance for each operation at the landfill facility to reflect the required information. If updating the current main entrance signage, it should have the types of waste accepted, phone numbers, including afterhours emergency number, and the types of waste that shall not be accepted at the C&DLF unit and the MSWLF, such as liquid waste, hazardous waste. This may be confusing and cause issue with the public if all put onto one sign, so be mindful and indicate the distinction of each site and its proper waste acceptance. County has additional signs but cumulatively doesn’t meet all rules. LCID - 15A NCAC 13B .0566 (14) - A sign shall be posted at the site entrance showing the site contact's name and phone number, the permit number, emergency contact information, and the waste types accepted for disposal at the site. CDLF - 15A NCAC 13B .0542 (j)(5) - Signs providing information on disposal procedures, the hours during which the site is open for public use, the permit number, and any information specified in the permit conditions to be included on the sign shall be posted at the site entrance. (6) - Signs shall be posted stating the types of waste that shall not be accepted at the C&DLF unit, such as liquid waste, hazardous waste, and municipal solid waste. MSWLF - 15A NCAC 13B .1626 (6) (e) - Signs providing information on disposal procedures, the hours during which the site is open for public use, the permit number, and any information specified in the permit conditions to be included on the sign shall be posted at the site entrance. (f) - Signs shall be posted stating the types of waste that shall not be accepted at the MSWLF unit, such as hazardous waste or liquid waste. Main entrance signage. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 13 3. CDLF is still in the expanded cell on the west end of the CDLF. Working face was small, compact and no unapproved waste was visible during inspection. Good job. Older cells had good cover on most of the side, but the top needs improved cover and vegetation established. This additional cover and proper vegetation is needed to prevent erosion. Spring is the proper window for establishing perennial grass cover on these areas of the CDLF, MSW and LCID, but a fall grass should be used until that time in conjunction with other erosion control measures. Older equipment cannot be stored on top CDLF, please remove. THIS WAS MENTIONED BEFORE. Some mulch was staged but remember ADC soil/mulch 50/50 mix cannot be used for intermediate cover. Side slopes need mowing and some eroded areas/seeps repaired. 15A NCAC 13B .0542 (f)(3) - Areas that will not have additional wastes placed on them for three months or more, but where final termination of disposal operations has not occurred, shall be covered and stabilized with vegetative ground cover or other stabilizing material as provided for in Subparagraph (4) of this Paragraph. CDLF working face viewed from MSW FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 13 Current working face in new cell, older cells to left of frame. Soil staged for cover, good job. On top CDLF - Older equipment need removal and ruts need fixing. THIS WAS MENTIONED BEFORE. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 13 South side slopes North side slopes, need mowing. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 13 North side slope seep/eroded are, please fix. Needs mowing. 4. Mulch is being taken from City of Lumberton as available for 50/50 mix for top dressing and erosion control and to help establish vegetative cover as needed on the landfills. If going to use for ADC, please follow rule/Guidance document for additional requirements. Records were provided by Ms. Kristina, showed loads of mulch, where it came from, how many loads etc. Also, cover logs for the other landfills were provided. Cover logs need to indicate what type of cover and time. Be sure and document according to CDLF/MSWLF rule, depending on where it goes for cover etc. Remember, the CDLF should be covered when the waste disposal area exceeds one-half acre and no less than once weekly and follow the Approved ADC guidance from the Section. Also, ADC soil/mulch 50/50 mix cannot be used for intermediate cover and be sure covering with soil is at the proper frequency with using ADC 50/50 mix. So older closed cells which will not have waste will need proper soil covering, sloping, and vegetation established etc. 15A NCAC 13B .0542 (f)(2) - Except as provided in Subparagraph (4) of this Paragraph, the owners and operators of all C&DLF units shall cover the solid waste with six inches of earthen material when the waste disposal area exceeds one-half acre and no less than once weekly. Cover shall be placed at more frequent intervals if necessary to prevent the escape of waste and the attraction of vectors and scavenging, and to minimize fires and the generation of odors. A notation of the date and time of the cover placement shall be recorded in the operating record as specified in Paragraph (n) of this Rule. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 13 CDLF Cover Logs, need time and type of cover indicted in future logs. 5. Treatment and Processing Area is for accepting pallets. Some unapproved wastes were visible, such as painted pallets. Please remove to appropriate disposal site. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 13 6. Mobile Homes are still being deconstructed in same area. Only three were present during visit. Previous discussions with Ms. Kristina onsite were that the County will demo the MH if not enough for contractor to come and deconstruct. Two were taken on 12/2/2022 and one on 12/2/2022. 7. White goods and scrap metal storing area was in fair condition. Anything containing CFCs should be upright until the gas is removed. All waste should be on concrete pad, which most was this time, good job. 8. Tire collection area was in good shape with three trailers. All were orderly stacked in trailer. Good job. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 13 Tire trailer. 9. Ground water and methane monitoring wells were visited, along with some of their records reviewed. Three methane sampling events this year so far, another happening before end of year. There were exceedances and the County did not report this to the Section. All exceedances should be communicated to the Section/Hydrogeologist within 24 hours. Wells visited included: MMW 21, MMW20, MW30, MW23, MMW15, MW21, MMW10, MW4, MMW8, MW16, MMW22, MMW4, MMW4A, MW11, MW3R. Methane monitoring is done in house with a handheld meter. It is not calibrated but once a year (failed some of the tests indicated on the form). Some of the methane monitoring results were over the 25 % LEL for Methane and should have been reported to Solid Waste Section for multiple monitoring events this year. Records of the three sampling events for methane this year were sent to Elizabeth Werner via email by David Powell on 12/7/2022, along with recent calibration and photo of the instrument the county used to do their self-monitoring. Mr. Walters also indicated that the blower and flare system for venting methane was down for maintenance and no backups were available. Mr. Powell indicated that the County needed to report this to Division of Air Quality if it conflicted with the permit with DAQ. Robeson County Landfill needs to communicate with Elizabeth Werner on Methane Monitoring and the previous sampling results for 2022. (elizaebth.werner@ncdenr.gov or 919.707.8253). A remediation plan needs to be constructed and implemented, please work with Elizabeth Werner on this plan. A backup method for venting/blowing should be available to operate the system when down for maintenance in accordance with approved plans/rules. The county may need to look into outsourcing this monitoring or getting some technical assistance from a consultant to understand the expectations of rule and approved plans and there implementation. 15A NCAC 13B .0544 (d)(3) If explosive gas levels exceeding the limits specified in Subparagraph (1) of this Paragraph are detected, the owner and operator shall: (A) upon discovery of detection, notify the Division and take any steps that may be necessary to ensure protection of human health, such as evacuation or monitoring of offsite structures for explosive gases; (B) within seven days of detection, place in the operating record the explosive gas levels detected and a description of the steps taken to protect human health; and (C) within 60 days of detection, implement a remediation plan for the explosive gas releases, place a copy of the plan in the operating record, and notify the Division that the plan has been implemented. The plan shall describe the nature and extent of the problem and the FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 13 proposed remedy. The latest approved Landfill Gas Monitoring plan submitted by the County stated, “In the event that an exceedance of the regulatory levels is observed, the NC DEQ shall be notified within 24 hours of the observation, and the monitoring results and a description of the steps taken to protect human health, shall be placed in the facility’s operating record within seven calendar days of the observation.” MW12 (MSW SIDE), with new well beside. Old well should be removed if abandoned according to rule. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 13 MMW10 (MSW SIDE)– a road has been made right beside this well, roadway should be moved away, and protection posts installed to protect. 10. Records reviewed consisted of: Scrap tire certification and receipts for individuals and businesses, Leachate pH meter calibration log, SIU discharge permit for leachate, leachate sample analysis’s and volumes treated, cover logs for all facilities, Waste Screenings, scrap metal removal receipts from Martin Metals in Lumberton NC, Robeson County internal safety training logs, Random Monthly Volume Analysis for all waste taken onsite at the landfills and 2022 for yard waste/mulch, Asbestos disposal and abatement records/manifests. Waste Screenings should be increased. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 13 July 2022 12/2/2022 Certified Landfill Operators certificates: Dennis Currie - expires 6/16/2024, Josef Ivey –expires 6/16/2024, Angela Strickland – expires 6/16/2024, Frank Freeman – expires 6/16/2024. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 13 11. Corrective measures are necessary as result of this inspection. A follow up inspection will be conducted by Solid Waste Section Staff in about 60 days from inspection sent date. Please contact me if you have any questions or concerns regarding this inspection report. _______________________________________ Phone: 910-433-3350 _ David Powell Environmental Senior Specialist Regional Representative Sent on: 12/21/2022 X Email Hand delivery US Mail Certified No. [ _] Copies: Jason Watkins, Field Operations Branch Head Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Head – 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