7803-MSWLF-1997_INSP_20230928

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 12
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: September 28, 2023 Date of Last Inspection: August 9, 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 [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 Frank Freeman, Crew Leader 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

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 12
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .1626 (8) - Drainage control and water protection requirements. (a) Surface water shall be diverted from the operational area. (b) Surface water shall not be impounded over or in waste.
Section Staff inspected the MSWLF on 8/9/2023 and observed exposed waste, windblown wastes across the cells and along the limits of disposal beyond the working face. A time frame of thirty days from date of receipt of the 8/9/2023 inspection report, which was 8/21/2023, was given to implement corrective actions. Upon follow up on 9/28/2023, exposed and windblown waste was still not adequately addressed across the cells to meet rule. In addition, water was observed impounded over waste next to the working face. Please address as weather and conditions allow.
Working face with standing water on right side inside limits of disposal.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 12
Close up of standing water, windblown and exposed wastes.

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 4 of 12
ADDITIONAL COMMENTS
1. The purpose of this visit was to do a follow up inspection of the Robeson County Landfills and corrective actions previously identified. Previous violations are still occurring, and new violations noted. It’s understood the methane gas extraction system is now operating as designed with blowers installed and flares are able to operate.
Good job. It’s understood some 3 new staff are being hired within the next week or two and should help assist with corrective actions.
2. Across phase 5 there was still 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. This should be done moving forward as well. In addition, eroded soil needs to be replaced to appropriate depths, compacting and proper sloping to restrain erosion while shedding stormwater, and establishing vegetation across the new cell and areas across older cells.
Working face with standing water impounded over waste on right.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 12
Some cover has been added and one inmate in rear of photo picking up windblown.
Photo taken on access road to working face at cell transition. Working face out of frame to left. Cell 6 on right and cell 5 on left. Some soil was added but more is needed. Erosion along north side of older cells along cell 6
transition.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 12
3. Phase 5 windblown wastes are spread out across the phase and into the next phase. 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 the 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, such as tv electronics, was previously visible where phases 5 and 6 meet and just down slope from the newly installed signage at entrance to working face. Remove any unapproved waste to an appropriate disposal location. Restore phase 6 and its protective layer to design specifications. This was mentioned before but weather/conditions have prevented all work from being completed according to Mr. Gene.
Phase 5 looking into phase 6.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 12
Phase 5 looking into Phase 6.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 12
4. Soil should be added to cover exposed waste across cells at MSW in new and older cells. Intermediate cover should be in place, and replaced where needed, on older cells not receiving waste for 12 months and erosion rills should be replaced. Vegetation should then be established to restrain erosion. 15A NCAC 13B .1626 (2) - 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: (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 working face is behind and left of photographer. This is looking from cell 5 back towards previous older cells. Erosion rills, and windblown/exposed waste in new cells need cover.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 12
The working face is behind and right of photographer. This is looking from cell 5 back towards previous older cells. Erosion rills, and windblown/exposed waste in new cells need cover.
The working face is behind and right of photographer. This is looking from cell 5 back towards previous older cells. Erosion rills, and windblown/exposed waste in new cells need cover.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 10 of 12
5. Mowing across the MSWLF should be increased. This was mentioned in previous inspections. Please address and increase the frequency moving forward.
West end of MSWLF

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 11 of 12
East side MSWLF

North side MSWLF
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 12 of 12
6. Please continue to communicate and follow guidance from Section hydrogeologists. 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 ([e-mail] or 919.707.8253). Always confirm notification has been received.

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.” 7. Corrective measures are necessary as result of this inspection. A follow up compliance inspection will be conducted by Solid Waste Section Staff within about 60 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: 10/17/2023 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