7803-MSWLF-1997_INSP_20230412

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 11
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: April 12, 2023 Date of Last Inspection: December 6, 2022
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 (RCSW) Gene Walters, Robeson County Solid Waste (RCSW) STATUS OF PERMIT: PERMIT TO CONSTRUCT - 7803-MSWLF-1997 – ROBESON COUNTY LANDFILL PHASE 5, PHASE 6
PERMIT TO OPERATE - 7803-MSWLF-1997 – ROBESON COUNTY LANDFILL PHASE 2, PHASE 3, PHASE 4;
12/6/2021 - Permit to Operate 7803-MSWLF-1997 – ROBESON COUNTY LANDFILL Phase 5, Area 1 12/13/2022 - Permit to Operate 7803-MSWLF-1997 – ROBESON COUNTY LANDFILL Phase 5 and Phase 6 (this was reissued to address wording and some issues with 3/17/2022 PTC/PTO.) 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 Inspection – Follow Up.
STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .1626 (2) (a) - UNRESOLVED 2. 15A NCAC 13B .1626 (11) (c) – UNRESOLVED 3. 15A NCAC 13B .1626 (4)(c) – UNRESOLVED

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 11
OBSERVED VIOLATIONS: NA

ADDITIONAL COMMENTS
1. The purpose of this visit was to do a follow-up inspection of the Robeson County Landfills. The county has hired
contractors to pick up windblown waste. This is in addition to inmates when they are available. Contractors have been unavailable for the past few days as well as inmates. Older cells have been mowed. Working face was not too large during inspection. 2. Windblown has improved much, as well as exposed waste on the MSWLF. Most of these areas have been addressed. However, with no inmates recently and new contractors not able to pick up in recent days, there are some areas in which windblown is still an issue as well as exposed waste. It’s apparent that much soil cover and mulch top dressing has been added around the MSWLF. In addition, the mulch accepted contained other waste comingled in the waste mulch from other facilities. The County needs to remove the comingled waste and use it with ADC or top dressing or not use the mulch to mix with soil to make ADC and add it as waste and cover appropriately. This should be addressed quickly so the contractor hired to hydro seed older cells and side slopes can seed the areas and establish vegetation. The worser areas were surrounding the current work face and mostly towards the northern limits of the MSWLF Phase 5 and the previous working face. It was agreed onsite that within 2 weeks of the inspection date a couple of photos confirming that the exposed waste and windblown would be addressed and sent to Mr. Powell. When using mulch as top-dressing for erosion control, vegetation establishment etc., and not ADC, be sure to keep this limited to three inches of thickness maximum. Please remember, mulch itself cannot be used as cover, but can be in a
50 mulch /50 soil mix as ADC. ADC mulch cannot be used as intermediate cover. Once these issues have been addressed then the violations can be resolved. There is also a seep that the county has tried to fix many times and it still needs to be addressed. Contact engineer/consultant for technical assistance on addressing this seep. 15A NCAC 13B .1626 (2)(d) - Areas that will not have additional wastes placed on them for 12 months or more, but where final termination of disposal operations has not occurred, shall be covered with a no less than one foot of intermediate cover.
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 11
Phase 5/6 and working face. Windblown an issue.
Working face close-up view. Plastic drums are used as traffic control.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 11
North of current working face, windblown/exposed waste in previous working face area.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 11
Some windblown along NW corner of limits of MSW.
The northern side slopes look better.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 11
Atop older phases, near center, with some windblown/exposed waste that was comingled in waste. Please address.
Atop older phases, near center looking approximately west, with some windblown/exposed waste that was
comingled in waste. Please address.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 11
South side slope looking good.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 11
East side has had some soil and mulch added as well. Above grade from access roadway there is still a seep needing repair. Please address. 3. The discussion onsite was that cover logs have been adjusted to show what type of cover was being used and the time, as requested. Please follow up and be sure onsite staff are still making these notations to meet the rules. Mr. Gene explained that a contractor has been hired to hydro seed older cells and will be coming soon.
Fix all erosion beforehand so they can be hydroseeded as well.
4. Air monitoring for county landfills has now been contracted out to Hunt Environmental Associates. There have been some exceedances since my last visit and in 2022 in general. Documents were provided and forwarded to Elizabeth Werner showing calibration of equipment for the contractor, sample results and a financial assurance corrective cost form. All exceedances should be communicated to the Section/Hydrogeologist within 24 hours. Robeson County Landfill needs to communicate with Elizabeth Werner on Methane Monitoring and the previous sampling results since last year ([e-mail] or 919.707.8253).
Always confirm notification has been received. Ms. Kristina forwarded email confirmation of contacting Elizabeth Werner on 4/13/2023 and confirming she has received documents since December 2022. However, a remediation plan needs to be constructed and implemented, if not done so already, so 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 blower/flare system is still down, although equipment to repair is onsite. County is trying to hire a mechanic to install/repair the system. During the onsite discussion, an extension for repairing the blower was requested for 30 days from inspection sent date to allow time for a mechanic to be hired and time to install the equipment, which is onsite already. If this cannot be achieved, then a backup plan for contracting out this service should be implemented in time to meet this timeframe.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 11
15A NCAC 13B .1626 (4)(c) - If explosive gas levels exceeding the limits specified in Sub-item (a) of this Item are detected, the owner or operator shall: (i) 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; (ii) 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 (iii) 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 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.” 5. Signage still needs to be updated to reflect new rules and permits. The onsite discussion was that the signs have all been ordered to reflect new changes and the County is waiting for the contractor to finish them. Previous
recommendations were as follows: “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.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 10 of 11
Main entrance signage (photo taken last inspection).
6. A MW was identified on the SE corner of the MSWLF, which was right alongside of a temporary access roadway that has been created. This road is now mostly not used and has had some concrete barricades put in place to protect the integrity of the well. Good job.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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7. Corrective measures are necessary as result of this inspection. A follow-up inspection will be conducted by Solid Waste Section Staff in about 30 days from the inspection sent date. 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: 4/19/2023 X Email Hand delivery US Mail Certified No. [ _]
Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section
Sherri Stanley, Permitting Branch Head – Solid Waste Section
Elizabeth Werner, Hydrogeologist – Solid Waste Section
Kristina Locklear-Cummings, Robeson County Solid Waste Kellie Blue, County Manager, Robeson County