7803-CDLF-1997 _INSP_20230412

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: 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: 34.79222 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: 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 – Follow up. 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 10
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, so some ground has been lost on windblown pickup. Older cells have been mowed. 2. 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 issues 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

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Main entrance signage (photo taken last inspection).

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 10
3. CDLF is still in the expanded cell on the west end of the CDLF. The working face was not too large, was being compacted and no unapproved waste was visible during inspection. Good job. There was some exposed waste on the NW corner. Please cover appropriately ASAP. Older cells had good cover on most of the sides with some patchy areas of erosion. Soil cover was staged on top of the older CDLF cells and equipment that was requested to be removed has mostly been removed. There were still some rims and a wheel left and Mr. Gene instructed an employee to remove those items during inspection. 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 everything can be hydroseeded as well.
CDLF working face.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 10
NW corner, EOW marker and some exposed waste.
Working face from older cells.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 10
Some rims and wheels need removal from older cells.
South side slope.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 10
4. The Treatment and Processing Area is for accepting pallets. No unapproved waste was visible. Good job.
Pallet T and P collection.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 10
5. Mobile Homes are still being deconstructed in same area. Approximately nine were present during the visit. Previous discussions with Ms. Kristina onsite were that the County still relies on a contractor for deconstruction. Dates were not noted on the homes as required by permit condition. Always put date of acceptance on MH even if plan is to deconstruct very quickly. Permit Attachment 3, Part VII, 88 - All mobile homes must be deconstructed within 45 days from
acceptance into the deconstruction area. The date of receipt at the landfill shall be posted on the mobile home or its frame.
MH with no date.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 10
6. White goods and scrap metal storing area were in good condition. Anything containing CFCs should be upright until the gas is removed. All waste should be on concrete pad, which the waste was during inspection, good job.

7. 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. 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

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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.”
8. Corrective measures are necessary as a result of this inspection. A follow up inspection will be conducted by Solid Waste Section Staff in about 30 days from 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