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Home My WebLink About7803-CDLF-1997 _INSP_20230928FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 13 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: 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: 34.79222 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 Frank Freeman, Crew Leader 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 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 13 OBSERVED VIOLATIONS: 1. 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: (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. 2. 15A NCAC 13B .0542 (g) Windblown waste requirements. Methods such as fencing and diking shall be provided within the area to confine solid waste that is subject to be blown by the wind. At the conclusion of each operating day, all windblown material resulting from the operation shall be collected and disposed of by the owner or operator. Section Staff inspected the CDLF on 8/9/2023 and observed exposed waste and windblown wastes across the cells and along the limits of disposal beyond the working face. The working face was estimated to be larger than one half acre at the time. Some larger waste items were left atop the older cells, such as PVC piping, needing removal to 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, although site had improved. Exposed waste that needs proper cover inside the limits of disposal or it is considered windblown and needs to be picked up and taken to the working face to receive proper cover. Please pick up all windblown waste and cover any exposed waste with proper cover of six inches of earthen material, after compaction and sloping 3:1. Moving forward windblown should be picked up daily, and all waste covered appropriately 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. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 13 View is ~ S, at the NE entrance to new cell. Older cell on left and new cell to right. Windblown waste along older cells well beyond the working face. Working face out of view on right out of frame. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 13 View is close up at edge of disposal of previous working face on NW corner of new CDLF cell. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 13 View is ~ S, on NW corner of new CDLF cell at edge of waste; Waste left exposed from previous working face. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 13 View is looking ~ NE atop older CDLF, MSWLF is visible in rear of photo; Larger items are still present on CDLF needing to be removed and taken to working face for disposal. Please remove items before they are mixed or cover in place appropriately. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 13 3. 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: (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. Section Staff inspected the CDLF on 8/9/2023 and observed the older cell on the western side slope had erosion and needed proper cover per rule. 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 these items were still not addressed. View is ~ E, looking at older cell from new cell. Exposed waste and windblown visible across new cell and older. Proper soil and vegetative cover are needed on the western side of older cells and parts of new cells. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 8 of 13 View is ~ W, from atop older cell looking down slope into new cell of CDLF. An eroded area with some exposed waste needs proper soil and vegetative 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 9 of 13 ADDITIONAL COMMENTS 1. The purpose of this visit was to do a follow up of the Robeson County Landfills. Mr. Walters identified still being down staff but hopeful in immediate future for new hires to begin and assist with normal operations as well as corrective actions. However, windblown waste/exposed waste was an issue surrounding working face cell and across the cell. If compliance cannot be maintained with current staffing or equipment, then additional should be contracted to meet the need. Contracted groups should continue to be searched for until appropriate contractors can be put in place to operate as needed. Older cells still need mowing, although mowing has begun in other areas, more frequent mowing is needed across landfills at site. CDLF new cell from atop the western end of older cells. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 13 2. CDLF is still in the new 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. Working face FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 13 3. Access road to top of older cells was previously identified as severely eroded. Some soil has been added and graded, good job. Please maintain. 4. Previous equipment had caught in fire in new cell and was still present but has now been removed. Good Job. Equipment burned from 5/8/2023 Fire, now removed. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 13 5. Mobile Homes are still being deconstructed but much waste from the operations has been removed. MH deconstruction area on right as turn into site from access road. MH deconstruction area on left as turn into site from access road. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 13 6. 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