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Home My WebLink About7803-CDLF-1997 _INSP_20230809FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 17 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: 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: 34.79222 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 17 ADDITIONAL COMMENTS 1. The purpose of this visit was to do a comprehensive inspection of the Robeson County Landfills. An operator was onsite during the inspection visit. The county had inmates onsite, but at MSWLF, to pick up windblown waste during inspection. However, windblown waste/exposed waste was an issue surrounding working face cell and across the cell. A compactor has been lost due to fire recently, but another has been contracted. 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. 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 in other areas, more frequent mowing is needed across landfills at site. CDLF as seen from the MSWLF. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 17 South slope of CDLF older cells. Needs mowing. North slope of CDLF. Needs mowing. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 17 2. Signage has been updated and installed at entrance to working face. Photos were sent by Ms. Kristina after install. Good job. RCSW provided photo of signage at CDLF. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 17 3. 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. 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. CDLF Cover logs CDLF waste screening FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 17 MOLO - Ms. Kristina Martin Metals Receipt 4. CDLF is still in the expanded cell on the west end of the CDLF. The working face was too large but was being compacted and slowly covered during visit. Minimal unapproved waste was visible during inspection. SE corner of new cell also had a few tires that need removal. There was exposed waste across the new cell in addition to working face. Please cover appropriately ASAP across new cell and current working face. Cover logs show that cover is done about every 7 days. Given the exposed waste and busy working face, cover is needed much more frequently. The proper depth isn’t being achieved either so please address properly moving forward. Older cells had cover with vegetation on most of the sides, with some patchy areas of erosion, but the western end of the older cell had some exposed waste. This shows there is insufficient cover and cover is not meeting rule requirements. Please add soil cover to address exposed waste and establish vegetation once proper cover and sloping on western side of older cells. Time is also supposed to be on the cover logs. 15A NCAC 13B .0542 (f) Compaction and cover material requirements. Solid waste shall be managed within the disposal area throughout the life-of-site and post-closure care period to prevent the escape of waste and the attraction of vectors and scavenging, and to minimize fires and the generation of odors. The owner or operator shall comply with this requirement using the following compaction and cover procedures: (1) The owner or operator shall compact the solid waste. (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. (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. (4) Alternative materials or an alternative thickness of cover are allowed with prior approval of the Division if the owner or operator demonstrates that the alternative material or thickness prevents the escape of waste and the attraction of vectors and scavenging and minimizes fires and the generation of odors without presenting a threat to human health and the environment. Alternative materials that have been approved by the Division for use at any C&DLF may be used at all C&DLFs in accordance with G.S. 130A-295.6(h1). FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 17 CDLF working face out of frame to left and beyond site to right along edge of waste. More was covered during inspection. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 17 Exposed waste across new cell, beyond working face, needing proper covering. Trucks in rear of photo is location of working face. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 17 Atop older cell CDLF on west end, looking west to new cell. Working face is visible in far right corner, and upfront is down slope of older cell to new cell, which shows erosion and improper cover, please address. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 17 5. Access road to top of older cells has eroded much and should be repaired. Older larger waste items on top need to be removed, such as large pipe, buckets, etc. Please remove any exposed waste or cover appropriately. Add soil where needed to achieve proper cover and sloping to not impound water over waste. Large pipe on top older cells. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 17 6. Previous derelict equipment was removed from older cells. However, recently a piece of equipment caught fire while at new cell. The Division was not notified, and no report was sent. All fires at landfill should be notified, not just ones in working face or associated with waste. Fire report was submitted on 8/16/2023. 15A NCAC 13B .0542 (i)(4) - Fires and explosions that occur at a C&DLF require verbal notice to the Division within 24 hours and written notification within 15 days. Written notification shall include the suspected cause of fire or explosion, the response taken to manage the incident, and the action(s) to be taken to prevent the future occurrence of fire or explosion. Equipment burned from 5/8/2023 Fire. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 17 7. The Treatment and Processing Area is for accepting pallets. A couple small painted items were visible, please be sure and remove and dispose properly. Good job. Pallet T and P collection. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 17 8. Mobile Homes are still being deconstructed in same area. Approximately eight were present during the visit and all had dates, good job. Previous discussions with Ms. Kristina onsite were that the County still relies on a contractor for deconstruction and all MHs are inspected for asbestos, mercury and additional hazardous wastes before work begins. Please be mindful of windblown waste while deconstructing. All waste should be removed after deconstruction and ensure no waste left behind and mashed into ground from equipment causing disposal. MH deconstruction area. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 14 of 17 MH deconstruction – address windblown wastes. 9. Scrap tire collection uses several trailers a month. Three onsite during inspection. Scrap Tire Trailers. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 15 of 17 10. White goods and scrap metal storing area was spread out on and around concrete pad. Anything containing CFCs should be upright until the gas is removed. All waste should be confined to concrete pad and managed more orderly. Attendant should be onsite to organize waste dumping. Perhaps pickup should occur more often as well to keep waste from piling up so much. White goods and scrap metal 11. 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 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 16 of 17 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. 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 proposed remedy. MW11 GW-4405-A MMW15 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 17 of 17 12. 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