78J-LCID-1990_INSP_20220107

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID X YW Transfer Compost SLAS COUNTY: Robeson
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 78J-LCID-1990
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: January 7, 2022 Date of Last Inspection: August 11, 2020
FACILITY NAME AND ADDRESS: Lumberton LCID Landfill Saddletree Road (SR 1531), Exit 20 Hwy I-95, north of Hwy 211 GPS COORDINATES: Lat.: 34.668073 Long.: -79.021612 FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Mr. Rob Armstrong O: (910) 671 – 3851; M: (910) 734 - 9851
Email address: [e-mail] FACILITY CONTACT ADDRESS: Mr. Rob Armstrong City of Lumberton
PO Box 1388 Lumberton, North Carolina 28358

PARTICIPANTS: David Powell, SWS Dale Pittman, City of Lumberton LCID Operator
Jeff Haliburton, City of Lumberton STATUS OF PERMIT: Currently operating under Permit issued August 18, 2021; Expires August 18, 2026.
PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: NA

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 9
OBSERVED VIOLATIONS:
1. 15A NCAC 13B .0201 (c) - No solid waste management facility shall be established, operated, maintained, constructed, expanded, or modified without a valid permit issued by the Division for the specified type of activity. It is the responsibility of every owner or operator of a proposed solid waste management facility to apply for a permit for the facility. The term "owner" shall include record owners of the land where the facility is located or proposed to be located and holders of any leasehold interest, however denominated, in any part of the land or structures where the facility is located or proposed to be located.

2. Current Permit Attachment 1, Part 1, 6 - Construction and operation of this solid waste management facility shall be in accordance with the North Carolina Solid Waste Management Rules, 15A NCAC 13B; Article 9 of the Chapter 130A of the North Carolina General Statutes (NCGS 130A-290, et seq.); the
conditions contained in this permit; and the approved plan. Should the approved plan and the rules conflict, the Solid Waste Management Rules shall take precedence unless specifically addressed by permit condition. Failure to comply may result in compliance action or permit revocation.
At the time of inspection, there was a mulching/composting of yard waste and yard trash operation onsite, that was previously permitted under the 78J-LCID-1990 permit. It was indicated in the renewal application, submitted February 2020, on Page 40, section 3.4 last sentence, “The City plans to eliminate the mulching
operation by year¬end 2020.” This operation has not ceased and it’s no longer a permitted activity at this site. This is also a violation of the current approved permit for altering the operations plan that was approved.

ADDITIONAL COMMENT
1. David Powell, with the Section, inspected the Lumberton LCID on January 7, 2022. The facility is operating under a new permit which does not include the approximate four-acre mulching operation on NW corner of the property. It was indicated in the renewal application, submitted February 2020, on Page 40, section 3.4 last sentence, “The City plans to eliminate the mulching operation by year¬end 2020.” This operation has obviously not ceased and it’s no longer a permitted activity at this site. A Permit amendment, modification or an entirely new permit may be required. The City of Lumberton should discuss options with their engineer firm/consultant and communicate with the Sections Engineer Project Manager Benjamin Jackson for this county immediately.
Email - [e-mail] Office – 919-707-8234.

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 3 of 9
2. During previous visit, at the entrance, the facilities sign stated this was a “Demolition landfill”. This was requested to be fixed to state the correct information and has been done as requested. Good job.

3. Facility does have a gate and an attendant was present. Section staff met Mr. Dale Pittman and Mr. Jeff Haliburton while onsite. Mr. Pittman has large containers for storing unapproved wastes he collects as he works onsite. Glass, scrap metal etc. are still being put into waste containers on side of road. Good job.

4. Previously, there was concrete stored on site waiting for enough to be crushed. Now there is no concrete and
the area has been graded some. Good job.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 9
5. Site had a yard waste mulching area PREVIOUSLY approved for mulching. There was a good amount of material present on day of inspection as well as a small amount of unapproved materials comingled in the yard
waste. Three larger windrows were mulched around October 2020 according to onsite staff. Be sure and not to stockpile more than the previously approved 8,000 cubic yards as well as only accept “leaf and limb” waste. Remove all unapproved waste. Manage and grade so waste is not in water and so that leachate
doesn’t leave or run outside of the yard waste area. City personnel who dump should be aware of what wastes are not approved. Follow guidelines of previous permit condition until new guidelines are approved. While onsite, Mr. Powell reached out to Robeson County for possibly utilizing some of the mulch for mixing with soil for 50/50 ADC on landfill at Robeson County.
PREVIOUS - Facility Permit Issued September 29, 2010 Attachment 3, Part I (7) - A mulching operation at this facility is permitted in a three-acre area northwest of Phase III in accordance with the approved plan referenced in Attachment 1, Part II of this permit (List of Documents For the Approved Plan). Only leaf and limb yard waste shall be accepted. The waste shall placed in wind rows not to exceed 20 feet in height, 25 feet in width and 200 feet in length. The total volume shall not exceed 8,000 cubic yards before the waste is processed.
6. Any waste, no matter the age of it or how well broken down it is, is still waste and should be utilized according to rule or disposed of at the appropriate site. If the City wishes to continue to operate any type of yard waste/trash facility, then it must properly utilize that waste. It will need to be sent to a boiler, be composted, or disposed of at appropriate landfill for disposal. Since it contains yard trash is must meet 15A NCAC 13B .1406 rules before it can go to anyone in the public or to a landfill for disposal of that waste type. Since it has yard trash it may not be beneficial to a boiler. A suggestion by Mr. Powell was to work with Robeson County with taking mulch/compost for them to mix with soil 50/50 for ADC on their landfills. This
could be a mutually beneficial relationship. It would require the City to continue taking, processing and staging their yard waste/trash and then mulching it but staying within the limits and rules.

Depicts front of mulching area near state highway side.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 9
7. Mulch area needs to be built up and graded so leachate doesn’t run off and neither will storm water pond. Leachate, which is any water that contacts waste, must be managed onsite and not discharge. This site should
meet 15A NCAC 13B .1404 rules with the design of the pad in which any operations are conducted. Waste in water is a violation and should be prevented as well.

Standing water in low are that needs to be built up.
Leachate near edge of road and unapproved waste pile from it being removed form yard waste on right.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Back windrow along ditch/property line and may need additional buffering. Follow what new permit states as correct buffer.

8. Upon arriving at the working face of the LCID, the front side slopes (north slope) were visibly steeper than 3:1 ratio. Working face was clean and mostly covered on top. Side slopes should be 3:1 and slopes that exceed 3:1 need to be re-graded to meet this requirement. Also, further grading may be needed to allow any surface water to be diverted from the working face and not impounded over waste. Other sides of the LCID looked good, with good cover and sloping ~ 3:1. No trees or shrubs at this time, please continue to stay on top of this. Good job.

Permit Attachment 3, Part V, 17 - Solid waste in the landfill shall be compacted. Slopes shall not exceed a ratio of three horizontals to one vertical (3:1) at any time.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 9
9. Section staff discussed the need of sloping and covering the LCID more often as well as someone always being present at the yard waste area on NW side of property, to the left once you enter the facility, to stop any bad
loads. Mr. Pittman explained equipment breakdowns, Covid and not enough staffing was an issue.

10. Mr. Haliburton did emphasize the cleaning out of the storm water ponds recently, good job. Be sure they are still in accordance with the Sedimentation and Erosion Control Plan (SECP) that’s is approved.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 9
11. On north side, middle way, in the corner of where the LCID turns, is a steep area in which should be 3:1 slope and inside the EOW boundaries. The rest of the north, south and east sides are covered, sloped and
grassed pretty well.

12. Edge of Waste (EOW) markers were supposed to be installed already, however, they are not visible around the LCID currently. These should be installed on all corners and sides so that one can be seen to the next. Suggest large tall white PVC pipe. Be sure these are installed in the correct approved waste boundary locations. They should be installed for next cell as well. Flood plain/wetland marker should be installed on back side of LCID to ensure where this area is located.
Current Permit Attachment 2, Part V, (9)(b) - The disposal unit boundary must be accurately delineated with permanent markers in accordance with 15A NCAC 13B .0201(g).
13. Corrective actions are needed as a result of this inspection. The City of Lumberton needs to address the permitting issue immediately with Section Permitting and start this process. Corrective actions should be completed within 30 days from the date this inspection was received. A follow up inspection will need to be conducted around that time or soon after to confirm these corrective actions have been completed. Please keep Mr. Powell updated on progress and should there be any issues require more time can be
discussed as they arise.

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: 910 433 - 3350 _ David Powell Environmental Senior Specialist
Regional Representative
Sent on: 1/19/2022 X Email Hand delivery US Mail Certified No. [ _]
Copies: Andrew Hammonds, Eastern/Western District Supervisor - Solid Waste Section Benjamin Jackson, Engineering Project Manager– Solid Waste Section