7803-MSWLF-1997_INSP_20240715

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: July 15, 2024 Date of Last Inspection: April 23, 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: Gene Walters, Robeson County Solid Waste David Powell, NC DEQ, Solid Waste Section Ben Kelly, NC DEQ, Solid Waste Section James Wallace, NC DEQ, Solid Waste Section 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 (2)(d) - UNRESOLVED
3. 15A NCAC 13B .1626 (7) - URESOLVED
4. 15A NCAC 13B .1626 (11) – UNRESOLVED
OBSERVED VIOLATIONS: NA
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 8

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. Also, this visit was to introduce permit engineer assigned to Robeson County, with the Section,
James Wallace, and the Hydrogeologist, Ben Kelly, assigned to the Robeson County Landfill to county staff. Their contact is as follows: James Wallace - [phone] or [e-mail]; Ben Kelly - [phone] or [e-mail]. Section staff road and walked to the top of the older phases, looked down from older phases to working face, and around the perimeter of the entire MSW while also walking the area between Phase 5 and 6. The access road to the working face was busy and congested with a vehicle being stuck, so Section staff stayed out of the way during inspection. An extension of 45 days was given, and that time was not met before this inspection was conducted. In addition, since that visit, and before the extension expired, another 45 days was requested by Robeson County to continue improving and working on corrective actions onsite. That request was granted, which would be a compliance dated 9/2/2024 for addressing previously identified violations. 2. Mr. Walters informed Mr. Powell that the methane gas capture system has still not been fixed, although they are working
on it. Mowing is still needed in some areas and should be more frequently done, once windblown is removed in that area.
3. Windblown had recently been picked up, during inspection, around the facilities but it was still an issue. In addition, one bag of waste was in some ponding water. Please remove ASAP to working face. Older windblown pickup bags have been discovered, in recent in sections, which added to the windblown issues. This was a violation in recent
inspections. Please educate those assisting with windblown pickup to not leave trash in water, and to always gather the bags after each day and take them to working face.
NE corner of MSW, looking west along northern slope, windblown bag in water.
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

Page 3 of 8
4. The working face was viewed during inspection and was of an appropriate size. Better soil cover is needed across the open phase and some areas of severe erosion/older phases across the MSWLF. Waste that’s visible is either exposed and needs cover or is windblown and needs to be picked up.
Working face

Across phase 5, near the working face, was exposed waste/windblown.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 8
NE corner of MSW, needs mowing.
NW corner slope fixed.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 8
NW corner, looking east along the northern slope.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 8
NW corner, near access road to working face. Ditch full of eroded soil, with windblown/exposed waste.
5. The transition from Phase 5 into 6 has much eroded soil from the surrounding phases, along with much waste in and around the area where the two phases meet. Section permitting will determine if there are additional steps before allowing waste to begin being deposited into phase 6. The rain cover has been damaged and it is unknown if the liner, or other parts, are damaged or if the site is still meeting design specifications. Discussions with Mr. Walters, before leaving, were that it was the counties intention to remove some of the soil eroded into the phase before putting down the first “fluff” layer, when the time comes, but there is time to wait for Section permitting to determine next steps before the county needs the space. A new mine was also discussed as the county is getting ready, which will allow for more soil cover. The NW corner of the MSW has had the sloughed area addressed, mostly. Cover and sloping have been done with most of the waste either picked up or covered. Please be sure all waste stays inside the limits of disposal. Additional EOW markers are needed, one visible to the other, Along the edges of this phase.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 8
Transition from phase 5, on left, and phase 6, on right.
Close up view in the transition between phases with windblow/exposed waste.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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6. Robeson County landfill still 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 and maintain compliance. It’s the responsibility of the county to operate and maintain these facilities in accordance with its permit/rule. The county has requested two extensions for completing the corrective actions in the time allotted. The corrective actions needed are not just an immediate need but should be maintained moving forward to meet rules as the landfill continues to operate every day moving forward.
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.
7. Corrective measures are necessary as a result of this inspection and should be completed by September 2, 2024. Failure to bring the site into compliance may result in further enforcement actions up to and including a compliance order with penalties. 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: 7/29/2024 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 Benjamin Kelly, Hydrogeologist – Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste Kellie Blue, County Manager, Robeson County