7803-MSWLF-1997_INSP_20210812

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF X LCID YW Transfer Compost SLAS COUNTY: Robeson
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 7803-MSWLF-1997
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: August 12, 2021 Date of Last Inspection: June 9, 2021
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: David Powell, NC DEQ, Solid Waste Section Andrew Hammonds, NCDEQ, Solid Waste Section
Ben Jackson, NCDEQ, Solid Waste Section Elizabeth Werner, NCDEQ, Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste
Gene Walters, Robeson County Solid Waste Mousa Maimoun, Labella Hannu Kemppinen, Labella
STATUS OF PERMIT: PERMIT TO CONSTRUCT - 7803-MSWLF-1997 – ROBESON COUNTY LANDFILL PHASE 5, PHASE 6 7803-CDLF-1997 – ROBSEON COUNTY CDLF, C&D LANDFILL EXPANSION PERMIT TO OPERATE - 7803-MSWLF-1997 – ROBESON COUNTY LANDFILL PHASE 2, PHASE 3, PHASE 4 7803-CDLF-1997, ROBESON COUNTY CDLF – OVER CLOSED LANDFILL 7803-MSWLF-1985 7803-MSWLF-1997 Issued February 4, 2021; Life of Site expires - December 29, 2057*
7803-CDLF-1997 Issued February 4, 2021; Life of Site expires - December 31, 2057*
PURPOSE OF SITE VISIT: Comprehensive Follow Up Inspection – Notice of Continuing Violation to follow.
Pre-Operation Visit Cell 5/6 MSWLF

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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STATUS OF PAST NOTED VIOLATIONS:
1. 15A NCAC 13B .1626 (2) (a) – UNRESOLVED 2. 15A NCAC 13B .1626 (11) (c) - UNRESOLVED 3. 15A NCAC 13B .1626 (8) (d) – UNRESOLVED 4. General Statute § 130A-309.10. (f) (7) - RESOLVED 5. General Statute § 130A-309.10. (f) (12) - RESOLVED 6. General Statute § 130A-309.10. (f) (15) – RESOLVED
Notice of Violation July 6, 2021
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .1626 (2) (a) – Except as provided in Sub-Item (b) of this Item, the owners or operators of all MSWLF units must cover disposed solid waste with six inches of earthen material at the end of each operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing
litter, and scavenging.

2. 15A NCAC 13B .1626 (11) (c) – Methods such as fencing and diking shall be provided within the area to
confine solid waste subject to be blown by the wind. At the conclusion of each day of operation, all windblown material resulting from the operation shall be collected and returned to the area by the owner or operator.

3. 15A NCAC 13B .1626 (8)(d) - Leachate shall be contained within a lined disposal cell or leachate collection and storage system. All leachate shall be treated, as required by the receiving facility, prior to discharge. An NPDES permit may be required prior to the discharge of leachate to surface waters, as provided by 40 CFR Parts 258.26 and 258.27.
At the time of the inspection, there were still large areas of exposed waste and windblown litter observed sporadically along the top of the landfill, along beside the haul road, of the MSWLF at the time of this inspection. All exposed waste must be covered in accordance to the rules at the end of each working day and should be logged daily according to permit/rule. Cover issues have been mentioned in prior inspections and appears to be an ongoing problem at this facility. Ruts on top were visible, which may hold storm water and create additional leachate. When weather allows please address.
Section staff discovered additional leachate outside of the edge of waste (EOW), right beside bottom of access road to working face of MSWLF and outside of the leachate collection system. Same area as 6/9/21 leachate
release. This is on east side of LF but south side of the access road, within the perimeter storm water ditch. It was very easily discovered by inspectors riding up roadway to MSW working face. Source was same as before, and that it had come from uphill along road. It is likely that LF staff could see the area where the leachate was
impounded and exposed waste along the access roadway every trip to and from the working face of MSW. Additional site training for staff may be needed so that staff is aware of what is unacceptable in operations plan/permit in order to respond quickly to areas of noncompliance. Exposed waste should be
covered and leachate removed along with surrounding soil and replaced with clean soil. Clean all trash out of ditches. Follow sampling plan and leachate release guidance in permit/operations plan. The County needs to document all corrective actions on this and other issues. This area of EOW needs markers installed and grass mowed. Shrubs have been cut since last inspection but were left onsite once cut. At least two additional seeps were visible by inspectors in this area, one in center of MSWLF access road up to working face and a second further up hill. Dust was also an issue during the inspection and these areas were wet soaked. A seep along the west side of the LF, near bottom and where new cells tie into current cell, was
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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being excavated for repair. This area has been severely eroded due to storm water and improper cover, which has led to the comingling of storm water with leachate that is now collected on the covers of Cell 5 and 6 expansions. Sampling should be done before removing or pumped into the leachate collection system. Section staff discussed with County staff. County staff stated that all wastewater would be put into collections system. This inspection was also for a Pre Operation meeting for Cell 5 and 6. After inspecting the site, Mr. Jackson is considering only permitting a partial opening Cell 5 to assist with addressing the exposed waste and to help
control further erosion. Much work needs to be done to fix the problems at Robeson County Landfill before further opening of future cells will be permitted.
View is of excavated area of leachate release during last inspection on 6/9/2021. New leachate was discovered during inspection. This ditch is perimeter of EOW from MSWLF on right. Leachate collection tanks on left. Still no EOW markers visible.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 12
View is looking uphill at source of leachate release in previous photo. Working face uphill and to left out of frame.
View is just right of previous photo. Shows seep in MSWLF access roadway and working face. Another seep is located below the right bulldozer further uphill, but has fresh soil applied to it.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 12
View is ~ south, looking at working face from distance. Ruts, exposed waste and windblown.

View is ~ west, atop MSWLF completed cells. Ruts, exposed waste and windblown. Older cells in need of vegetation once other issues are addressed.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 12
View is ~ west. Looking from cell 4 at older completed cells on left, cell 5/6 expansion on right. Exposed
waste/windblown is visible. A seep is being repaired from a severely eroded area which leads storm water into new cell expansion.
View is ~ west, slightly more NW view. Looking from cell 4 at older completed cells on left, cell 5/6 expansion on right. Exposed waste/windblown is visible. Storm water contaminated with leachate ponded on cell expansion cover.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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View is ~ north west. Exposed waste/windblown waste visible.

ADDITIONAL COMMENTS
1. Purpose of visit was to do a follow up inspection on the Robeson County Landfills and the recent Notices of Violation Corrective Actions, as well as Pre Operation inspection for the new cells for the CDLF/MSWLF. Mr. Powell revisited the site on 9/15/2021 to look at the progress. 2. Inspectors drove around entire LF along bottom and top, getting out periodically and walking to inspect compliance issues and hard to see areas of the LF. While driving up to the working face, inspectors observed a large amount of leachate impounded beside the access road within the perimeter ditch. Once the leachate was being addressed by site staff, inspectors rode up to and around the working face to continue the inspection of the facility while staying out of the way of the working equipment and trucks.
3. At the time of this inspection, inspectors observed what was reported to be by County staff, a leachate clean out left open along the east side. Please check for damage and ensure all related structures are maintained and
closed properly.
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 such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 12
4. Operations are currently still in Phase 4 on MSWLF. Cells for Phase 5 and 6 are constructed. Eroded soils, leachate and storm water from active working face and downslopes of other inactive cells are washing on to and pooling on the liner of newly constructed Cells. The erosion and storm water issues should be addressed quickly to protect new cell liner integrity.
View is ~ SE. Shows Phase 5 and 6, Phase 4 in background.
5. Staff walked to center of where cells meet and point of severe erosion from current cell into new cells. Seep repair in background, exposed waste and erosion up front. Concerns were that the liner may be damaged or
compromised with leachate or contaminated storm water potentially going underneath the liner. A partial opening of Cell 5 is being considered to assist with the repairs between these two cells.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 12
Cell 4 on left and cell 5 behind view of photo. Exposed waste, damaged erosion control structure in need of repair, and seep repair in background.
View is of Cell 4, looking ~ east. Severe erosion and exposed waste are visible. Fix cover and slope when weather and conditions allow.
6. Last inspection noted, “MW21 can be easily moved by hand and is holding on only by the well pipe. This
should be addressed right away and repaired in accordance with 15A NCAC SUBCHAPTER 02C. Area
around the wells and sampling points should be mowed regularly. Be sure and document any actions.” Discussion with County staff were that it has not been repaired.
Permit Attachment 3, Part I, (20) (e). - Documentation of well completion, development details, repair, abandonment, and other activities associated with each groundwater and landfill gas monitoring well must be maintained in the facility operating record.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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7. More frequent mowing is necessary to manage the woody and lush vegetation. Having good thick grass/vegetation is preferred over low cut grass. This will need to be done in addition to establishing new vegetation to maintain the LF slopes and compliance with the rules. Careful attention should be given around wells to ensure no damage and the soil around them is not eroding away. Section and County staff should be able to see EOW markers at all times while the MSWLF still has the vegetative cover it needs to protect from erosion.
8. At the time of this inspection, it was observed that the working face was appropriate size. Some soil was staged for cover, along with tarps.
9. Erosion rills were also visible around top of MSWLF. As stated in previous inspection, “Please cover and slope
all areas accordingly when conditions allow. Address erosion, by adding soil, structures, vegetation, etc. Again look at SECP and Ops plan.” 10. Dust was very bad at this facility at the time of this inspection. Dust control measures must be implemented (15A NCAC 13B 1626 (6)(d)). 11. Before leaving, Section staff sat down with County Staff Mr. Gene and Mrs. Kristina, and Labella staff to discuss their findings at all facilities, corrective actions that should follow and permitting’s opinion on new cells opening. Any permit issues, problems or operation alterations that Robeson County may wish to change should be directed to Benjamin Jackson. Any changes need to be approved before they can take place. Contact Information Section Permitting Branch Engineer Benjamin Jackson – [e-mail] / 919 -707 – 8234 office.
Staff issues aside, it is Robeson Counties responsibility to operate the landfills in accordance with the rules. Failure to bring the site into compliance may result in enforcement actions up to and including fines, or additional requirements for the facility. The County should consider all options including if necessary, contracting out the operation of this site or possibly modifying the hours of operation until
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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staffing and equipment are sufficient to maintain compliance. 15A NCAC 13B .1604 (2)(I) Proper Operation and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance include effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality control procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary, to achieve compliance with conditions of the permit. 12. There will need to be multiple step approach to addressing these issues. Leachate seeps and proper soil cover should be addressed immediately to counter other leachate issues and from adding to excess windblown waste. Follow Leachate Release Sampling and Analysis Guidance document. Additional grading and erosion control measures may need to be added to the areas where there are reoccurring erosion issues. Repair current erosion control structures. Refer to approved plans and or discuss with Engineers for recommendations on correcting these issues. Areas not being used shall have vegetation established, and that should be good perennial grasses. Check the entire perimeter of LF and be sure all
EOW markers are in place correctly, add more were needed. Mow where necessary around the LF. Inspect all wells and cleanouts while checking for damage. Follow up with Cumberland County and other sources for mulched/composted material to use with soil as ADC cover. Additional sources were discussed later via phone with Ms. Kristina, such as Town of Fairmont and Moore County. 13. Mr. Powell revisited MSWLF on 9/15/2021 and noted much cover and seeding had taken place. Much more cover is needed on top/older cells. There is still waste that is visible. It is either windblown and should be picked up and removed to working face so it can be covered or it is exposed waste and should be properly covered in place. Working face was of proper size. There was still a small suspected seep visible near access road leading up to working face. This has been a leachate prone area in the past. Mowing has begun on west side at toe of slope. This is good, much more mowing is needed. Some areas need reworking to reach the desired 3:1 slope requirement. Cover was actively being applied and spread while onsite. 14. Corrective measures to bring this facility into compliance should be complete within 30 days’ receipt of this inspection report. A follow up compliance inspection will be conducted by Solid Waste Section Staff to follow up on these corrective actions. Failure to meet the conditions for compliance may result in additional Compliance Actions.

Please submit a Sampling Plan for Section approval prior to sampling. The proposed plan shall be submitted in electronic format sent via email and meet the following requirements: 1. Include a map/aerial photo depicting area of impact and proposed sampling locations; 2. Provide a description of the proposed sampling methodology; and 3. Describe proposed subsurface soil sampling and surface water sampling (if applicable) at specific locations, including background soil and upstream water locations, to evaluate the extent of the
potential environmental impacts from the release(s) at the facility; a. Subsurface soil samples shall be collected between one to two feet below ground surface; b. Discrete soil samples shall be collected. Composite samples will not be accepted; and c. All soil and surface water samples shall be analyzed by a NC certified laboratory for 40 CFR Part 258 Appendix I parameters (VOCs and Total Metals), total phosphorus, sulfate, nitrate, and pH.
After Section approval of the sampling plan, the plan shall be implemented within seven (7) days. Within 10 business days after receiving the analytical results from the laboratory, submit documentation regarding the sampling event which shall include the following:
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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1. A summary of the leachate release, actions taken to address the release, and the release assessment; 2. A map/aerial photo depicting the sampling locations;
3. A table of the surface water analytical results compared to the NCDWR Surface Water Quality Standards & Protective Values; 4. A table of the subsurface soil analytical results compared to the NCDEQ Preliminary Soil Remediation Goals (PSRGs). Both the Residential Health Based and the Protection of Groundwater PSRGs must be met; 5. The associated laboratory reports from the NC certified laboratory including the chain of custody and QA/QC results; 6. The sampling methodology, if different from the proposed plan; and 7. Conclusions and recommendation. Submit the results to Elizabeth Werner, Hydrogeologist, 1646 Mail Service Center, Raleigh, NC 27699-1646, [e-mail], 919-707-8253, Environmental Senior Specialist, [e-mail], 919-280-5135. Please contact me if you have any questions or concerns regarding this inspection report. _______________________________________ Phone: [phone] _ David Powell Environmental Senior Specialist Regional Representative
Sent on: 9/20/2021 X Email Hand delivery US Mail Certified No. [ _]

Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Andrew Hammonds, Eastern District Supervisor - Solid Waste Section
Benjamin Jackson, Engineering Project Manager – Solid Waste Section Elizabeth Werner, Hydrogeologist – Solid Waste Section Chris Hollinger, Compliance Officer –Solid Waste Section Elizabeth Werner, Hydrogeologist – Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste Kellie Blue, County Manager, Robeson County