4701-MSWLF-1981_INSP_20240821

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 7
UNIT TYPE:
MSWLF COUNTY: HOKE
MSWLF X goods PERMIT NO.: 4701-MSWLF-1981
FILE TYPE: COMPLIANCE

Date of Site Inspection: July 1, 2024 Date of Last Inspection: March 5, 2024
FACILITY NAME AND ADDRESS: Hoke County Closed MSW Closed MSW Landfill
700 C.C. Steel Rd., Raeford, NC 28376 GPS COORDINATES: Lat: 35.008782 Long: -79.221380 FACILITY CONTACT NAME AND PHONE NUMBER: April King Locklear, Solid Waste Director Hoke County Solid Waste [e-mail] 910-705-2514 FACILITY CONTACT ADDRESS:
Same as above
PARTICIPANTS: David Powell – NCDEQ, Solid Waste Section
Helen Adams, Hoke County Supervisor STATUS OF PERMIT:
4701-MSWLF-1981 – Closed
PURPOSE OF SITE VISIT: Comprehensive Inspection – Follow Up STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .0510 – UNRESOLVED 2. Facility Closure Permit and Letter dated December 12, 1995, Item #2 – UNRESOLVED 3. Facility Closure Permit and Letter dated December 12, 1995, Item #4 - UNRESOLVED
OBSERVED VIOLATIONS:
1. 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
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 7
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.

2. 15A NCAC 13B .1631 (b) - Monitoring wells shall be designed and constructed in accordance with 15A NCAC 02C.

3. 15A NCAC 02C .0108 (p) - Each non-water supply well shall have permanently affixed an identification plate. The identification plate shall be constructed of a durable, waterproof, or rustproof material and shall contain the following information: (1) well contractor's name and certification number; (2) the date the well was completed; (3) the total depth of the well; (4) a warning that the well is not for water supply and that the groundwater may contain hazardous materials; (5) the depth to the top and bottom of each screen; and (6) the well identification number or name assigned by the well owner.

Some issues, going back as far as 12/19/2023 inspection, are still not addressed regarding wells. Wells ID plates are still missing some information, or it was illegible or not visible, as required by rule, such as construction, depth, year, warning etc. Some ID plates are not permanently affixed. Some well vaults have damaged lids or no lids. Repair as required to ensure well integrity. There is still limited access to some wells with overgrown vegetation. Trash consistent with old caps and plastic sleeves from sampling have been discarded onto the ground and should be removed. The markers placed to mark the wells are inconsistent, different markers were 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 located by Section staff with a map. In addition, the County has still not submitted the sampling data via the new Equis EDD format. Please contact Section Hydrogeologist for guidance.

The item(s) listed above were observed by Section staff and require action on behalf of the facility 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
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 7
ADDITIONAL COMMENTS

1. David Powell with the Section visited Hoke County facilities for a follow-up inspection on corrective actions previously identified. Mr. Powell informed Ms. Locklear of the date he would be visiting. Mr. Powell upon arrival announced himself to Scalehouse operator and called Ms. Locklear, then began the inspection. Upon
follow up inspection for corrective actions, identified as far back as 12/19/2023, it was observed that they were still present and continuing. Mr. Powell walked the perimeter of the Closed MSW, and into the surrounding area attempting to locate wells, starting with the NE side along the access road to LCID. 2. A landfill cap maintenance plan has yet to be received, as previously requested. There was exposed and uncovered concrete/block wastes were still observed in several areas across the cap of the landfill. Overgrown vegetation inside the edge of waste and no tree/cap maintenance plan has been submitted for review as requested. Settled areas across the final cover system were still present, previously identified for restraining stormwater and allowing water to impound over waste. No water was observed impounded over waste during this inspection, but the settled areas need to be maintained such that surface water runoff occurs in a controlled manner and surface water cannot be impounded over waste. Landfill needs mowing currently across the cap, as weather allows.
Any surficial waste should be collected and recycled or disposed of properly. 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.

Mowing needed. Trees on right, inside EOW possibly.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 7

Settled area, previously held water over waste. Is overgrown and needs mowing.
Settled area, previously held water over waste. Is overgrown and needs mowing. Trees inside EOW or not? Unsure, due to no markers in this area.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 7
3. The current Edge of Waste (EOW) markers around the limits of disposal, and in some places lack thereof, are an issue. The EOW is unclear around most of the limits of disposal. EOW markers should be installed to properly mark the limits of disposal. All EOW markers should be consistent type and easily distinguishable as to what they represent. One should be visible to another. Any other areas where underbrush has taken of EOW markers should be mowed. Once limits of disposal have been identified, any large shrubs or tree vegetation should be removed. Landfill cap maintenance plan should address this issue moving forward.

T post fence line on left of view and then T post on right of view. Unsure which is EOW or if either is correct. The view is looking approximately SE from along the western side of closed MSW. Unknown and should be addressed.
T post fence line on right of view and then T post on left of view. Unsure which is EOW or if either is correct. The view is looking approximately NE from NW side approximately. Unknown and should be addressed.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 7
MW-3 with ID plate added and laid on concrete. Previous well cap trash nearby and older plate on concrete with some information visible. Please update. Lid broken but well head locked.

MW-7, trash left by sampling staff. MW-6 inside woods line. Access has been made but a good distance from well.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 7
4. In addition, the County has still not submitted the sampling data via the new Equis EDD format nor contacted Ben Kelly, [e-mail] or 919-707-8327, regarding the required sampling data for Hoke Closed MSW. This should be done immediately.

5. Corrective measures are necessary. A follow-up compliance inspection may be conducted by Solid Waste Section Staff within about 30 days’ receipt of this inspection report. All corrective actions should be addressed by that timeframe. 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: 8/21/2024 X Email Hand delivery US Mail Certified No. [ _]
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)