4701-MSWLF-1981_NOV_20240821

August 21, 2024

April King Locklear, Solid Waste Director Hoke County,
Closed MSW Landfill,
700 C.C. Steel Rd., Raeford, NC 28376
SUBJECT:
Compliance Inspection Report Hoke County Closed MSW
4701-MSWLF-1981
Hoke County
Dear Mrs. Locklear,

On July 1, 2024, David Powell, representing the State of North Carolina, Division of Waste Management Solid
Waste Section (Section), conducted a follow up inspection of the above referenced facility for compliance with
North Carolina solid waste statutes and rules, due to conditions noted during previous inspections, on December 19, 2023, and March 5, 2024. It was observed during the 7/1/2024 inspection that the previously identified
violations had not been corrected. Helen Adams was present and represented Hoke County during the 7/1/2024
inspection. Mr. Powell spoke with Ms. Locklear upon arrival via phone and at the conclusion of the inspection left a voicemail of findings and determinations, as well as, speaking with Ms. Adams. The following violation(s)
were noted:
15A NCAC 13B .0510 - The owner or operator of a closed construction and demolition landfill unit or
municipal solid waste landfill unit that is required to comply with this Rule in accordance with Rule .0531
of this Section or Rule .1601 of this Subchapter (collectively "site") shall comply with the post-closure care requirements specified in the permit conditions, the closure plan for the site, and the closure letter
or permit for closure issued by the Division to the site at the time of closure. The owner or operator shall
also comply with Section .0600 of this Subchapter. The owner or operator shall submit to the Division
upon written request any information or records that are required to be kept under either the permit
conditions, the closure letter, or the rules of this Subchapter. (Facility Closure Permit and Letter dated
December 12, 1995.)
Hoke County is in violation of this rule in that they have failed to follow the post-closure care
requirements and conditions within the closure plan. In addition, a landfill cap maintenance plan has
yet to be received, as previously requested.

B. Facility Closure Permit and Letter dated December 12, 1995, Item #2 – Management of Surface Water:
The owner and/or operator shall take the measures necessary to ensure that the closed site shall meet
the requirements of Rule .0503(2)(c). In addition, the landfill unit shall be maintained such that surface
water runoff occurs in a controlled manner, and surface water shall not be impounded over waste.

Hoke County is in violation of this rule, in that surface stormwater was previously identified as being
restrained during inspection, dated 3/5/2024, and impounding over the cap of the Closed MSW in
Hoke County Landfill
Notice of Violation
Page 2 of 4
8/21/2024
several locations. These settled areas have not been addressed and were still present during the 7/1/2024 inspection follow up.
Facility Closure Permit and Letter dated December 12, 1995, Item #4 – Final Cover System: The integrity
and effectiveness of the final cover system and any permanent erosion control devices must be
maintained. This could include making repairs to the cover as necessary to correct the effects of the
settlement, subsidence, erosion, or other events.
Hoke County is in violation of this rule, in that previously identified settled areas in the cap of the Closed
MSW during inspection, dated 3/5/2024, have not been addressed and were still present during the
7/1/2024 inspection follow up. Exposed waste, along with overgrown vegetation in those areas, either
needs to be covered appropriately or removed and disposed of according to waste type. Overgrown
vegetation needs to be removed.
D. Facility Closure Permit and Letter dated December 12, 1995, Item #8 (f) – Water Quality and Monitoring
Reporting Requirements: The water quality monitoring system for this facility shall be upgraded, for
post-closure monitoring purposes, in accordance with the proposed monitoring plan dated 19
September 1995 and consistent with the authorization letter from the Solid Waste Section
hydrogeologist dated 3 October 1995. Submittal of boring log(s), well completion record(s), well
schematic diagram(s) for each well and initial analytical sampling results (in accordance with sampling
parameters and methods outlined in paragraph “d” of this section) shall be submitted to the Solid Waste
Section within 90 days of the date of this closure letter. Based upon the results from the sampling event
for the new wells; if the data indicates that groundwater Quality Standards have been exceeded for
some chemical constituents at this facility, then additional water quality assessments may be necessary
in the future. Until the County is contacted by the Solid Waste Section about analytical results for the
new wells; the County will continue to monitor and sample ground water at its facility consistent with
Conditions b, c, and d of this section.

Hoke County is in violation of the above rules, in that although some minimal identification information
was added to well tags, some issues were still not addressed regarding wells. Wells are still missing
some information, or it was illegible or visible, as required by rule, such as construction, depth, year,
warning etc.; not all ID plates are permanently affixed, some have damaged lids or no lids. There is still limited access to some wells with overgrown vegetation, and trash surrounding some of the wells is still
present. The markers placed to mark the wells were inconsistent, different markers are being used, or
it is unknown if they marked the well or EOW or something else. Some wells cannot be found due to no marker, or the area is overgrown, and the well cannot be found by Section staff with a map. In addition,
the County has still not submitted the sampling data via the new Equis EDD format. Some of these
issues were identified as far back as 12/19/2023 during inspection.

Hoke County Landfill
Notice of Violation
Page 3 of 4
8/21/2024
Based upon the foregoing, Hoke County Landfill shall come into compliance with all requirements of the regulations in the Facilities Closure Permit and Letter dated December 12, 1995,
item # 2, #4 and #8(f), and 15A NCAC 13B .0510, .1631(b) and 15A NCAC 02C .0108 (p) by completing the
following at the Hoke County Landfill:
Any surficial waste should be collected and recycled or disposed of properly. Cap cover in these areas
should be repaired or replaced according to rule and final approved closure permit/documents.
2. The facility should develop a landfill cap maintenance plan, and submit to the Section, to include
periodic mowing or other maintenance as well as tree/stump removal protocols, when necessary.
County should contact Section Permitting’s John Nguyen, [phone] or [e-mail],
for requirements of the cap work involving removing large trees, removing stumps or root balls etc.

3. EOW markers should be evaluated and checked to ensure edge of waste is accurate and re-installed
where missing, one visible to the other, and following the limits of disposal and be of the same type of
marker, so they are distinguishable.

4. All wells should have appropriate access, with vegetation and all trash removed from around them,
markers installed to assist in marking their location, proper identification information on the well
according to rule.

5. All settled areas should be repaired according to rule and final approved closure permit/documents.

6. The County should submit the sampling data via the new Equis EDD format. Contact Ben Kelly,
[e-mail] or 919-707-8327, regarding the required sampling data for Hoke Closed
MSW.

7. Notify David Powell, Environmental Senior Specialist of completion of corrective actions. A follow up
inspection will follow after the 30 days’ receipt of this NOV deadline for corrective actions.

The violation(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.
Please keep me informed of your progress in this matter. Solid Waste Section staff will conduct a follow-up
inspection to verify that the operator has completed the requirements of this Notice of Violation.
If you have any questions regarding this matter, please contact me at (919) 280 - 5135 or e-mail
[e-mail].
Sincerely,

David Powell
Environmental Senior Specialist
Division of Waste Management - Solid Waste Section
Hoke County Landfill
Notice of Violation
Page 4 of 4
8/21/2024
Copies: Jason Watkins, Section Chief - Solid Waste Section Drew Hammonds, Field Operations Branch Head- Solid Waste Section
John Nguyen, Engineering Project Manager – Solid Waste Section
Perry Sugg, Environmental Compliance Branch – Solid Waste Section
Ben Kelly, Hydrogeologist – Solid Waste Section
Letitia Edens, Hoke County Manager (via email)