7803-MSWLF-1997_INSP_20240423

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
MSWLF X COUNTY: Robeson
PERMIT NO.: 7803-MSWLF-1997
FILE TYPE: COMPLIANCE

Date of Site Inspection: April 23, 2024 Date of Last Inspection: January 4, 2024
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 Gene Walters, Robeson County Solid Waste Kristina Locklear-Cummings, Robeson County Solid Waste 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
PURPOSE OF SITE VISIT: Comprehensive Inspection – Follow Up STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .1626 (2)(b) - UNRESOLVED 2. 15A NCAC 13B .1626 (7) - URESOLVED 3. 15A NCAC 13B .1626 (8)(a) – RESOLVED 4. 15A NCAC 13B .1626 (8)(b) – RESOLVED 5. 15A NCAC 13B .1626 (8)(c) – RESOLVED
6. 15A NCAC 13B .1626 (11) – UNRESOLVED

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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OBSERVED VIOLATIONS:

1. 15A NCAC 13B .1626 (1)(g) - Waste placement at MSWLF units shall be within the areal limits of the base liner system and in compliance with the effective permit.
2. 15A NCAC 13B .1626 (2)(d) - 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.

3. 15A NCAC 13B .1626 (7) - Erosion and sedimentation control requirements. Erosion control measures consisting of vegetative cover, materials, structures, or other devices shall be utilized to prevent silt from leaving the site and to prevent on-site erosion, and shall comply with 15A NCAC 04, which is incorporated by reference including subsequent amendments and editions.
4. 15A NCAC 13B .1626 (11) - 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. Upon inspection, previously identified violations are still occurring, as well as new violations being observed. Older windblown pickup bags were observed, that were left onsite, torn, and allowing waste to become windblown again. Along edge of waste (EOW), on NW corner of phase 5, additional erosion has occurred, taking waste and sediment beyond the liner and limits of disposal. In addition, a second area on the western side of the NW corner of phase 5 has also eroded severely. It also has taken sediment and waste beyond the liner across the perimeter roadway to a grassy area between two stormwater ponds. This soil and waste must be collected and returned to the limits of the
MSWLF. When water becomes comingled with waste, then it is considered leachate and not allowed to discharge or go beyond the leachate collection system. Although no active leachate runoff was observed during this inspection, conditions onsite may allow for such a discharge and should be addressed so that they cannot in the
future. The areas outside the EOW of to the north and west of Phase 5 and north of Phase 6 that have been impacted by the
discharge of sediment, and especially waste due to ongoing erosion, must have the soils and waste removed, collected, and returned to the landfill and these areas must be evaluated for potential contamination. Robeson County staff or their representatives must contact Solid Waste Section Environmental Compliance Branch staff Perry Sugg or Benajmin Kelly, 919-707-8258 / 919-707-8327 or [e-mail] / [e-mail], on addressing impacted areas outside the MSWLF liner system. The area of phase 5, and adjacent to phase 6, has continued to erode, along with windblown waste going into phase 6 and around the active phase. Severe erosion in and around the higher elevations of Phase 6, and surrounding phases, has damaged the rain cover. Due to the ongoing erosion issues at the edge of Phase 6, it may be necessary to evaluate the integrity of the liner in the impacted area to determine if it still meets design specifications before any fill operation begins. Facility staff should update the leachate management plan and utilize additional resources
to assist with pumping leachate from Phase 6 back to the holding tank, if not already done so. There are additional areas of exposed waste from erosion, improper cover, and vegetation establishment on the SE
side of the MSWLF. This area is an older access road going downhill from atop older phases. There is a second area on the east side of the older phase near the office, which is another older access roadway from atop the MSWLF. These two roads have erosion, exposed waste, improper cover and one has a leachate seep. These areas should be
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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addressed according to rules if not being used or are needed, with proper cover, vegetation establishment and seep repair. They can be left in such a manner as to not continue to be an issue while still providing access to the top of older phases for maintenance and repair.
NW slope of Phase 5 MSWLF – exposed waste with windblown and waste beyond EOW.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 14
Looking approximately west, along EOW, with waste beyond EOW. Exposed waste inside the EOW as well. This area was identified on 1/4/2024 inspection. A small amount of leachate can be seen beyond the liner.
Close up view of some of the waste eroded from Phase 5 outside of EOW that now covers larger area at bottom of slope.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 14
Windblown waste that’s beyond EOW markers, along with severely eroded soil into ditch around the limits of disposal on NW corner,
west side slope of phase 5.
The area in this photo is on the west side of the perimeter road, NW corner of MSW close to where phases 5 and 6 meet. It depicts erosion from phase 5/6 across road recently, in which waste and soil was washed across the road into the grassy area between two
stormwater ponds, deposited and left.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 14
The area in this photo is on the west side of the perimeter road, NW corner of MSW where phases 5 and 6 meet. It depicts erosion from phase 5/6 across road recently, in which soil and waste was washed across the road into the grassy area between two
stormwater ponds.
Close up view of eroded soil/waste in previous two photos.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 14
Windblown/exposed waste around vent, uphill towards older phases from phase 5/6 and near center of MSW.
Erosion and seep in eastern road, near office, leading to stormwater ditch outside EOW. Please address. Left photo is looking uphill and right photo is downhill.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 14
Inside phase 6, with waste that has eroded/windblown into it. Phase 5 is behind the view of this photo and older phases on left.
Windblown pick-up bags left to break open to become windblown again, also eroded wastes and new windblown. This photo is also
taken along inside of phase 6, with phase 5 uphill from the view of the photo and older phases out of frame on right.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 14
The view is from inside the edge of phase 6, near where it meets older phases, looking uphill toward phase 5 on left and older phases on right. Also, windblown and exposed wastes are visible across this area, erosion, and larges shrubs/weeds. Part of the damaged
rain cover sandbags are visible.
View along inside of phase 6, looking uphill to phase 5. Erosion of waste/soil into phase 6.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 10 of 14
Atop older phase on NE side of MSW, with windblown/exposed wastes. This is uphill from working face, which is just out of frame on the right. Phase 5 is on the right.

SE side of MSW eroded access road.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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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.
2. Mr. Walters informed Mr. Powell that the methane gas capture system was not in operation at the time of inspection. Mr. Powell advised Mr. Walters to inform DAQ and SWS Hydrogeologists. Currently the MSWLF does not have a Title 5 DAQ Permit. 3. Windblown had recently been picked up during inspection around the facilities but it was still an issue. 4. The working face was visited during inspection and was of an appropriate size. Waste was being compacted and worked into existing soil. Better soil cover is needed across the open phase and some areas of severe erosion/older phases across the MSWLF.
5. Signage previously noted at MSW, that was previously added as requested, is no longer installed or visible. Please install the required signage and maintain. Mowing the entire landfill has been noted as being needed in recent inspections. However, the MSWLF still needs to be mowed across much of the landfill. Some erosion rills need
addressing alongside slopes of MSW. Eroded areas should be repaired as soon as conditions allow after being observed. 6. Robeson County landfill has several compliance issues it needs to address. The county should enact whatever measures
necessary to make corrections and to bring the site into compliance. It’s the responsibility of the county to operate and maintain these facilities in accordance with its permit/rule. 15A NCAC 13B .0203 (d) By receiving solid waste at a permitted facility, the permittee shall be considered by the Department to have accepted the conditions of the permit and shall comply with the conditions of the permit. 15A NCAC 13B .1604 b(2)(I) Proper Operation and Maintenance. The permittee shall at all times operate and maintain all facilities and systems of treatment and control and related appurtenances which are installed or used by the permittee in compliance with the conditions of the permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures, in accordance with the conditions of the permit. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of the permit.
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
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Working face.
Approximately center of north slope MSWLF - Windblown pickup and large shrubs and weeds need mowing.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Western side slope with large tree/shrubs.
South side slope of MSW, with shrubs/trees along EOW.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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SE corner of MSW. Large shrubs/trees along ditch and eastern slope of older phase. 7. Corrective measures are necessary. 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: 5/13/2024 X Email Hand delivery US Mail Certified No. [ _]
Copies: Jason Watkins, Section Chief – Solid Waste Section Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Head – Solid Waste Section James Wallace, Engineer 2 – Solid Waste Section
Perry Sugg, Environmental Compliance Branch Head – Solid Waste Section Benjamin Kelly, Hydrogeologist – Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste
Kellie Blue, County Manager, Robeson County