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Home My WebLink About7803-MSWLF-1997_INSP_20230809FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 16 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: August 9, 2023 Date of Last Inspection: April 12, 2023 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 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 (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) - UNRESOLVED 2. 15A NCAC 13B .1626 (11) – UNRESOLVED 3. 15A NCAC 13B .1626 (4)(c) – RESOLVED FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 16 OBSERVED VIOLATIONS: NA ADDITIONAL COMMENTS 1. The purpose of this visit was to do a comprehensive inspection of the Robeson County Landfills. Previous rule violations were incorrectly quoted as pre 2021 rule change as 15A NCAC 13B .1626 (2)(a) and (11)(c). The correct rule quotation should have been just 15A NCAC 13B .1626 (2) and (11). The violation for 15A NCAC 13B .1626 (4)(c) will be considered resolved after speaking with Section Elizabeth Werner and reviewing records onsite. Methane monitoring results are being sent to Ms. Werner quarterly and Robeson County should continue to work with Section Hydrogeologists on air monitoring requirements in rule/permit. 2. During inspection, an operator was onsite at working face. The county had inmates onsite at MSWLF to pick up windblown waste during inspection, good job. However, windblown waste/exposed waste was still an issue surrounding working face and across the phase 5 area. Additional windblown countermeasures are needed immediately and going forward. Robeson County landfill is still down 5 employees. If compliance cannot be maintained with current staffing or equipment, then additional should be contracted to meet the need. Dust was an issue during inspection and should be addressed. Please follow up on water truck purchase. Additional land, adjacent to current land, has been purchased for a mine to dig soil for cover. Contact DEMLR for permits/requirements etc. Older cells need mowing, although mowing has begun, more frequent mowing is needed across landfills at site. 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 16 3. Signage has been updated and installed at entrance to working face. Photos were previously sent via email by Ms. Kristina after installing, good job. RCSW provided photo. 4. Records were reviewed during inspection including: operator certification and training, permits, plans, maps, monthly volume analysis, contingency plan, waste screening forms, scrap tire certifications, tire trailer request logs, MH records, asbestos logs and manifests, cover logs, scrap metal removal receipts, receipts for additional equipment rental and hauling of leachate to wastewater treatment plant. Scrap tires go to Central Carolina. Metals recycling and white good go to Martin Metal of Lumberton. Mr. Gene indicated that mulch was not being accepted and had not for some time. Current cover logs have a boiler plate statement of “MSW is to be covered daily with tarp and weekly with soil.” Rule 15A NCAC 13B .1626 (2) requires in part, “… six inches of earthen material at the end of each operating day, or 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.” ADC (Tarp) is being used daily but waste is not receiving the adequate soil cover. This i apparent by the amount of windblown and exposed waste onsite during multiple inspections. Robeson County must cover according to rule and ADC guidance, or it could potentially lose approval for ADC as cover and will have to use only soil. Increase soil cover and ensure staff are aware of the needs at the working face moving forward. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 16 Certifications: MOLO – Gene Walters expires 8/6/2023 and Kristina Locklear-Cummings expires 11/16/2025. Landfill Operations Specialist – Gene Walters expires 6/16/2024, Frank freeman expires 6/16/2024, Dennis Currie 6/16/2024, Josef Ivey 6/16/2024, Angela Strickland 6/16/2024, Kristina Locklear-Cummings 6/16/2024, Richard Maready 6/16/2024. MSW Cover logs FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 16 MSW Waste Screening form Landfill Operations Certificate – Mr. Ivey. Receipt for leachate pump and haul 4/2023 – 1,989,411 gallons. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 16 5. Working face was maximum size during inspection. However, across phase 5 there was much windblown and exposed waste. Main working face was approximately on the NW corner of phase 5. Additional soil cover needs to be added currently across the phase, windblown removed from phase 5 and surrounding areas and more soil added during covering moving forward. Mr. Gene agreed to send photos via email soon after inspection. Main working face. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 16 6. Phase 5 windblown wastes are spread out across the phase and into the next phase, although not as bad as previously identified during last inspection. Stormwater, now leachate from comingling with windblown and exposed waste from surrounding phases/cells, has damaged the protective layer of phase 6. All liquid is being pumped and collected as leachate and then sent to wastewater treatment plant according to Mr. Gene. Proper soil cover, compaction and sloping in phase 5 would not just assist with exposed wastes and windblown in phase 5 but also into adjacent phase 6. Unapproved waste, tv electronics, where phases 5 and 6 meet and just down slope from the newly installed signage at entrance to working face. Please address windblown and exposed wastes. Remove any unapproved waste to appropriate disposal location. Restore phase 6 and its protective layer to design specifications. Phase 5 looking into phase 6. New signage in frame on right. TV just out of view downhill from sign. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 16 Phase 6 with TV and windblown into next phase with rainwater, now leachate, allowed to collect. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 16 7. It’s apparent that much cover has been added atop the previous older phase of the MSWLF since last visit, and vegetation is now taking hold. Hydro seeding was done shortly after last inspection. Mowing is currently needed in many areas across the older cells and has begun. As areas need repair, please replace proper amount of soil to keep proper depth of soil cover. 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. 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. North side of older cells of MSWLF. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 16 West side MSWLF FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 16 Southeast corner of MSWLF. Access road should have vegetative cover needed to restrain erosion. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 16 Atop older cells MSW. ADC and hydroseed doing well. View is approximately south. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 16 Atop older cells MSW. ADC and hydroseed doing well. View is approximately west. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 14 of 16 Transition from previous Phase into current phase 5. Erosion needing repair with soil to appropriate depth. 8. Wells for water and methane were visited during inspection. Ground water and methane monitoring is now done by Hunt Environmental Associates. Locks on wells were on all except one, with ID tags etc. The one with no lock was locked during inspection. Well visited included: MW-26, MMW-21, MW-12, MMW-19, MMW-15, MMW-11, MMW-10, MMW-4, MMW-4A, MW-11, MMW8, and GW well 4405-A. Elizabeth Werner requested via email, after inspection, for copies of monitoring reports from present back to 2019, please be sure those are sent ASAP. Air monitoring for county landfills has now been contracted out to Hunt Environmental Associates. All sampling results should be submitted quarterly to Elizabeth Werner until further notice. There have been some exceedances since my last visit and in 2022 in general. Documents were previously 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 (elizaebth.werner@ncdenr.gov or 919.707.8253). Always confirm notification has been received. The blower/flare system is still down, although equipment is installed it still needs additional install and repair to function. Mr. Gene explained a mechanic has been hired, which is why it is installed partly but a specific company needs to be hired to finalize the work to finalize repair. 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 15 of 16 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.” MW11 GW-4405-A MMW15 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 16 of 16 9. Corrective measures are necessary as result of this inspection. A follow up compliance inspection will be conducted by Solid Waste Section Staff within about 30 days’ receipt of this inspection report. Failure to meet the conditions for compliance may result in further Compliance Actions. Please contact me if you have any questions or concerns regarding this inspection report. _______________________________________ Phone: 919 – 280 - 5135 _ David Powell Environmental Senior Specialist Regional Representative Sent on: 8/21/2023 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