7803-MSWLF-1997_INSP_20241010

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: 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: 34.792527 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: 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: 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

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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OBSERVED VIOLATIONS:
1. 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.
Upon inspection, a previously severely eroded area was observed eroded from the active phase, to outside the limits of disposal and liner system. A small amount of waste was visible, as either windblown or was eroded from the active phase. Please remove all waste outside EOW, to the working face, and install erosion control measures to prevent waste and soil from eroding. ADC in conjunction with other methods may be necessary. Contact an engineering form or consultant to assist with appropriate measures, as well as approved plans.
North side slope with erosion outside EOW.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 11
2. 15A NCAC 13B .1626 (8)(c) - Solid waste shall not be disposed of in water.

During inspection, additional waste has windblown and eroded into Phase 6 and much waste was observed floating in water, now considered leachate.
Eastern side of inactive phase 6.
3. 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.
During inspection, windblown waste was observed on and around active phase 5, adjacent inactive phase 6, around entrance to Phase 5 and 6 on NW side of MSW, and atop inactive phase 4 along northeastern access
roadway.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 11
NW part of perimeter roadway, along north side of inactive phase 6.
Photo depicts active phase 5, working face out of view, to right of the view of the photo, and looking towards older closed phases.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 11
NE side of MSW, looking ~ east along the older phase access road that leads to main office and scalehouse, which are visible.

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 CDLF, over closed MSW, 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, leachate hauling receipts and logs, asbestos
manifests and 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.
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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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.
MSW Cover logs, with time. Asbestos disposal log. Waste Screening form for MSW. 3. Recently, a review of the past few years Facility Annual Reports showed waste disposal at the MSW has been more than the maximum permitted amount allowed for Net Waste Landfilled. The permit allows for a maximum of 94,250 tons per year. This increase in waste disposal has no doubt strained 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 II, 37 - Pursuant to Rule 15A NCAC 13B .0201(d)(1), this permit approves: b. The facility is approved to accept a maximum of 94,250 tons per year. Maximum variance shall be in accordance with NCGS 130A-294(b1)(1). The facility is permitted to receive non-hazardous solid waste generated within North Carolina, consistent with local government approval and as defined in G.S. 130-290 (a)(18a) and (35) except where prohibited by the N. C. General Statues Article 9 of Chapter 130A, and the rules adopted by the Commission for Health Services.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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4. Some of the wells were visited around the permitted facilities onsite. All had locks, lids, identification and ID plates. The wells inspected were: MMW17, MW12, MMW 15, MW10, and MMW 8.
MW10 5. Mowing is still needed in many areas around the MSW, and should be more frequently done, once windblown is removed in that area. 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.
Eastern side slope.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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NW corner, with some work done to manage stormwater and recent erosion.
Southern side slopes.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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6. The working face was within limits but exposed waste and windblown was an issue. 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.
Working face
Corner of phase 6 where phase 5 and older phases to south are eroding into phase 6.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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NW corner, along phase 6, with leachate being pumped back to collection and hauled to WWTP. Older cells need mowing, and some erosion addressed. 7. 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 multiple extensions for completing the corrective actions. 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. 8. Should the information be needed, section permitting engineer assigned Robeson County is James Wallace - [phone] or [e-mail]. 9. 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.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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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