7803-CDLF-1997 _INSP_20241010

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
MSWLF COUNTY: Robeson
MSWLF X goods X X PERMIT NO.: 7803-CDLF-1997 7803-MSWLF-1985
CDLF X Tire T&P / Collection X Tire Monofill Industrial Landfill DEMO SDTF

Date of Site Inspection: October 10, 2024 Date of Last Inspection: July 15, 2024
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
[e-mail] FACILITY CONTACT ADDRESS: PO Box 366 St. Paul’s, NC 28384

PARTICIPANTS: Kristina Locklear-Cummins, Robeson County Solid Waste Gene Walters, Robeson County Solid Waste
Wes Hare, NC DEQ, Solid Waste Section David Powell, NC DEQ, Solid Waste Section 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:
1. 15A NCAC 13B .0542 (f)(2) – UNRESOLVED 2. 15A NCAC 13B .0542 (f)(3) - UNRESOLVED 3. 15A NCAC 13B .0542 (l)(1) – UNRESOLVED 4. 15A NCAC 13B .0542 (l)(2) - UNRESOLVED

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 12
OBSERVED VIOLATIONS:

1. 15A NCAC 13B .0542 (l)(2) - Surface water shall not be impounded over or in waste.
During inspection, water was observed impounded over waste and waste from working face being pushed into the standing water. Cover is still an issue across the open phase, although cover has been added, and shedding stormwater, while restraining erosion, is still an issue.
Working face waste in standing water, impounded over waste.

Different view of water over waste from previous photo.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 12
ADDITIONAL COMMENTS
1. The purpose of this visit was to do a comprehensive inspection and follow-up of the Robeson County Landfills and corrective actions previously identified. Also, this visit was to introduce new Eastern District Supervisor Wes Hare, with the Section, to the staff of the Robeson County Landfill. The site has other permitted facilities nearby such as an active MSWLF and an LCID. All the facilities are behind a fence, lockable gate and have proper signage. Discussion onsite was about corrective actions, loss of three operators very recently, but a company called BMCO would be coming within 20 days for a preconstruction meeting for LCID. In addition, BMCO is scheduled to bring additional staff for operating heavy equipment to the landfill to maintain daily operation but also work on previously identified corrective actions. A 90-day extension was requested from the date of receipt of this inspection report. 2. Records reviewed during inspection included: permit, operations plan, previous inspection reports and correspondence, random monthly volume analysis reports, cover logs, DEMLR documents, ground water and methane reports and correspondence from Hunt Environmental Associates, scrap tire receipts and certifications,
waste screening records, and landfill operations certifications of training. Cover logs have time added as requested, good job.
Certifications included: MOLO – Gene Walters expires 8/6/2026; Kristina Locklear-Cummings expires 11/16/2025; Landfill Operator Specialist – Gene Walters expires 6/16/2024; Kristina Locklear-Cummings expires 6/16/2024; Frank Freeman expires 6/16/2024; Josef Ivey expires 6/16/2024; Angela Strickland expires 6/16/2024; Nacoda Locklear expires 9/6/2026; Justin Howell expires 9/7/2026. There is a shortage of operators at Robeson County Landfill to work the three landfills. A training class was scheduled for 10/2024 but was cancelled. Having operators at the working face that know the rules, permit and approved operations plans is essential to compliance and good landfill operation. In addition, it would be to the counties’ benefit to also have some additional training done in-house on the operators’ rules, permit and approved operations plan of the Robeson landfills, in which they are working.
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

Page 4 of 12
Operator Certificate CDLF cover logs. 3. Recently, a review of the last couple Facility Annual Reports showed waste disposal at the CDLF has been more than the maximum permitted amount allowed to be accepted for landfilling. The permit allows for a maximum of 30,000 tons per year. This increase in waste disposal has no doubt strained CDLF landfill operations, especially given the other issues at Robeson County Landfill. The County may need to adjust operations to
address corrective actions, allow for handling the additional waste coming to the landfill and communicate with Section Permitting to adjust permit, operations plan etc., for the actual waste disposal tonnage at the landfill. The County should communicate with Section Permitting before changing any onsite operation. Permit Attachment 3, Part III, 50 - b. The facility is approved to accept a maximum of 30,000 tons per year. Maximum variance shall be in accordance with NCGS 130A-294(b1)(1).
4. The working face was of max sizing at time of inspection. Waste was being compacted, covered and sloped. EOW markers were present and visible one to another, good job. However, cover is still an issue across the open new phase, either from improper covering or erosion, but cover should continue to be addressed. Waste placement in the landfill footprint, and the following cover, is not being utilized to the identified edge of waste, which also is marked along the stormwater ditch. Due to the nature of the shape of this construction, it will allow stormwater to be held and be impounded over waste, and not allowed to flow into stormwater ditch. Be sure waste placement, following cover and sloping is correct with approved plans and allow for surface water to run off in a controlled manner, while restraining erosion as designed.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 12
Working face.
Other areas across open phase needing cover.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 12
Western side slopes, erosion rills and exposed waste.
Northern slope mowed and looked good.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 12
South slope with EOW marker. 5. The previous access road to the top of older phases has had some soil added, as requested. Good job, but more is needed. The area and/or road should be vegetated if not receiving waste and can remain an access road, but this will prevent erosion from constantly being an issue and meet rules. There were also some eroded areas with some slight seepage on the western side of the older phases. This area has had recurring eroded
and seepage problems. Atop the older phases looked good and were vegetated.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 12
Access road, at bottom, to older phases.
Access road, at top, to older phases.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 12
Western side slope, at edge of new phases and older phases, eroded area and some seepage. Please address.
Atop older phases.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 10 of 12
6. The Mobile Home deconstruction area had two homes awaiting deconstruction and were within the max time frame based upon the date on the side. The area around these homes awaiting deconstruction needs to be cleaned better in the future.
MH deconstruction.

Waste left behind after deconstruction needing removal.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 11 of 12
7. The pallet area had some unapproved painted pallets in the pile, be sure and remove them
Pallets, with couple needing removal.
8. White good and scrap metal area is outside near LCID. Most white goods were upright waiting for enough to contact the vendor.

9. Scrap tires are accepted in trailers staged between LCID and CDLF. Two trailers onsite with room for more tires were observed during inspection. This area also has a storage building for fluorescent and mercury containing lights collected at convivence sites until there is enough for vendor to remove.

Scrap tire trailer.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 12 of 12
10. Robeson County landfill still has several compliance issues it needs to address. The county should enact 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 .0534 (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.
11. Should the information be needed, section permitting engineer assigned Robeson County is James Wallace - [phone] or [e-mail].

12. Corrective measures are necessary as a result of this inspection. A follow-up compliance inspection may be conducted by Solid Waste Section Staff within about 90 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: 10/18/2024 X Email Hand delivery US Mail Certified No. [ _]

Copies: Andrew Hammonds, Field Operations Branch Head - Solid Waste Section Wes Hare, Eastern District Supervisor – Solid Waste Section Chris Hollinger, Compliance Officer – Solid Waste Section
Sherri Stanley, Permitting Branch Head – Solid Waste Section James Wallace, Engineer 2 – Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste Kellie Blue, County Manager, Robeson County