The URL can be used to link to this page

Home My WebLink About7803-MSWLF-1997_INSP_20221206FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 22 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: December 6, 2022 Date of Last Inspection: January 27, 2022 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 harrell.walters@co.robeson.nc.us FACILITY CONTACT ADDRESS: PO Box 366 St. Paul’s, NC 28384 PARTICIPANTS: David Powell, NC DEQ, Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste (RCSW) Gene Walters, Robeson County Solid Waste (RCSW) 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* 7803-CDLF-1997 Issued February 4, 2021; Life of Site expires - December 31, 2057* 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 22 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. At the time of the inspection on 12/6/2022, large areas of exposed waste were observed sporadically along the top of the MSW landfill and the older cells, the new phase 5 and 6, and along perimeter haul road at the time of this inspection. All exposed waste must be covered in accordance with the rules at the end of each working day and should be logged daily according to permit/rule. Cover issues have been addressed in prior inspections and appears to be an ongoing problem at this facility. At the time of this inspection, windblown litter was observed along the top of the MSW landfill and the older cells, the new phase 5 and 6, and along perimeter haul road. Windblown litter should be picked up at the conclusion of each day and returned to the working face and covered appropriately. Better cover would solve this issue as well. Cover issues have been addressed in prior inspections and appears to be an ongoing problem at this facility. North side Phase 5, waste also outside EOW. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 22 North side phase 5, outside EOW. North side phase 6, outside EOW. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 22 East side slope, older cell, along entrance road to top from office. Phase 4, atop older cell. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 22 Older cells/phases atop MSW. Looking West. 3. 15A NCAC 13B .1626 (4)(c) - If explosive gas levels exceeding the limits specified in Sub-item (a) of this Item are detected, the owner or operator shall: (i) upon discovery of detection, notify the Division and take any steps that may be necessary to ensure protection of human health, such as evacuation or monitoring of offsite structures for explosive gases; (ii) within seven days of detection, place in the operating record the explosive gas levels detected and a description of the steps taken to protect human health; and (iii) within 60 days of detection, implement a remediation plan for the explosive gas releases, place a copy of the plan in the operating record, and notify the Division that the plan has been implemented. The plan shall describe the nature and extent of the problem and the proposed remedy. The latest approved Landfill Gas Monitoring plan submitted by the County stated, “In the event that an exceedance of the regulatory levels is observed, the NC DEQ shall be notified within 24 hours of the observation, and the monitoring results and a description of the steps taken to protect human health, shall be placed in the facility’s operating record within seven calendar days of the observation.” Methane monitoring is done in house with a handheld meter. It is not calibrated but once a year and failed some of the tests indicated on the form. Some of the methane monitoring results were over the 25 % LEL for Methane and should have been reported to Solid Waste Section for multiple monitoring events this year. Records of the three sampling events for methane this year were sent to Elizabeth Werner via email by David Powell on 12/7/2022, along with recent calibration and photo of the instrument the county used to do their self-monitoring. Mr. Walters also indicated that the blower and flare system for venting methane was down for maintenance and no backups were available. Mr. Powell indicated that the County needed to report this to Division of Air Quality if it conflicted with the permit with DAQ. Robeson County Landfill needs to communicate with Elizabeth Werner on Methane Monitoring and the previous sampling results for 2022. (elizaebth.werner@ncdenr.gov or 919.707.8253). A remediation plan needs to be constructed and implemented, please work with Elizabeth Werner on this plan. A backup method for venting/blowing FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 22 should be available to operate the system when down for maintenance in accordance with approved plans/rules. The county may need to look into outsourcing this monitoring or getting some technical assistance from a consultant to understand the expectations of rule and approved plans and there implementation. 3/23/2022 Methane Monitoring Record FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 22 9/30/2022 -10/6/2022 Methane Monitoring Record 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 22 ADDITIONAL COMMENTS 1. Purpose of visit was to do a comprehensive inspection on the Robeson County Landfills. Facility is secured by gate/fence and road made of all-weather construction. An operator was onsite during inspection visit. New compactor has been obtained, and a new dozer and truck will be leased to give the landfill needed equipment. The landfill was able to purchase an excavator as well, although not fully staffed a new operator will be starting within a week as well. Leachate was being hauled during inspection. A Notice of Violation to follow for observed repetitive violations. 2. Signage needs to be updated to reflect new rules and permit. The signage needs to be updated for new permit conditions for other facilities as well. The main sign can be altered to fit all, but to minimize confusion it is suggested to add a sign at the entrance for each operation at the landfill facility to reflect the required information. If updating the current main entrance signage, it should have the types of waste accepted, phone numbers, including afterhours emergency number, and the types of waste that shall not be accepted at the C&DLF unit and the MSWLF, such as liquid waste, hazardous waste. This may be confusing and cause issue with the public if all put onto one sign, so be mindful and indicate the distinction of each site and its proper waste acceptance. County has additional signs but cumulatively doesn’t meet all rules. LCID - 15A NCAC 13B .0566 (14) - A sign shall be posted at the site entrance showing the site contact's name and phone number, the permit number, emergency contact information, and the waste types accepted for disposal at the site. CDLF - 15A NCAC 13B .0542 (j)(5) - Signs providing information on disposal procedures, the hours during which the site is open for public use, the permit number, and any information specified in the permit conditions to be included on the sign shall be posted at the site entrance. (6) - Signs shall be posted stating the types of waste that shall not be accepted at the C&DLF unit, such as liquid waste, hazardous waste, and municipal solid waste. MSWLF - 15A NCAC 13B .1626 (6) (e) - Signs providing information on disposal procedures, the hours during which the site is open for public use, the permit number, and any information specified in the permit conditions to be included on the sign shall be posted at the site entrance. (f) - Signs shall be posted stating the types of waste that shall not be accepted at the MSWLF unit, such as hazardous waste or liquid waste. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 22 Main entrance signage 3. Mulch is being taken from City of Lumberton as available for 50/50 mix for top dressing and erosion control and to help establish vegetative cover as needed on the landfills. If going to use for ADC, please follow rule/guidance document for additional requirements. Records were provided by Ms. Kristina, showed loads of mulch, where it came from, how many loads etc. Also, cover logs for the other landfills were provided. Cover logs need to indicate what type of cover and time. Be sure and document according to CDLF/MSWLF rule, depending on where it goes for cover etc. Remember, all MSWLF units shall 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 prevent the escape of waste and the attraction of vectors and scavenging, and to minimize fires and the generation of odors, unless using ADC. Also, ADC soil/mulch 50/50 mix cannot be used for intermediate cover and be sure covering with soil is at the proper frequency with using ADC 50/50 mix. So older closed cells which will not have waste will need proper soil covering, sloping, and vegetation established etc. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 22 RCSW cover logs for MSW. 4. Operations have moved into Phase 5, with the working face being more or less in the center and max size. Working face is max size but exposed waste/windblown is scattered across many phases. Vegetation should be established in older cells that will not receive waste. Slopes are looking good, minus some erosion in areas. Mowing is needed in older cells as well. No waste is in Phase 6 currently. The “Fluff” layers have been added to phase 5 and windblown and exposed waste is an issue. Vegetative cover is needed once proper cover is achieved. Areas not being used shall have vegetation established, and that should be good perennial grasses. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 11 of 22 Working face on right, tires visible and should be removed. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 12 of 22 Working face, phase 5 with white protective layer of phase 6 visible in background. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 13 of 22 Phase 5 working face. Windblown an issue. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 14 of 22 Phase 6, leachate should be recaptured and treated according to approved plans. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 15 of 22 Phase 5 viewed from older cell on west side atop landfill. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 16 of 22 Southwest side slopes, need mowing. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 17 of 22 Southeast side, alternate road for trucks. MMW10 is visible and in way of this road. Protective barriers need to be installed and the road moved to prevent hitting it. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 18 of 22 Atop MSW, phase 4 looking to older cells/phases. Exposed waste and no vegetative cover. Please address. Atop MSW, phase 4 looking to older cells/phases. Exposed waste and no vegetative cover. Please address. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 19 of 22 Looking West from phase 4 into phase 5/6. Exposed waste visible, needs cover and vegetation established. 5. Ground water and methane monitoring wells were visited, along with some of their records reviewed. Cody Hunt with Envirochoice does GW sampling. Three methane sampling events this year so far, another happening before end of year. There were exceedances and the County did not report this to the Section. All exceedances should be communicated to the Section/Hydrogeologist within 24 hours. Wells visited included: MMW 21, MMW20, MW30, MW23, MMW15, MW21, MMW10, MW4, MMW8, MW16, MMW22, MMW4, MMW4A, MW11, MW3R. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 20 of 22 MW12 (MSW SIDE), with new well beside. Old well should be removed if abandoned according to rule. MMW10 (MSW SIDE)– a road has been made right beside this well, roadway should be moved away, and protection posts installed to protect. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 21 of 22 6. Records reviewed consisted of: Scrap tire certification and receipts for individuals and businesses, Leachate pH meter calibration log, SIU discharge permit for leachate, leachate sample analysis’s and volumes treated, cover logs for all facilities, Waste Screenings, scrap metal removal receipts from Martin Metals in Lumberton NC, Robeson County internal safety training logs, Random Monthly Volume Analysis for all waste taken onsite at the landfills and 2022 for yard waste/mulch, Asbestos disposal and abatement records/manifests. Waste Screenings need to be increased. Certified Landfill Operators certificates: Dennis Currie - expires 6/16/2024, Josef Ivey –expires 6/16/2024, Angela Strickland – expires 6/16/2024, Frank Freeman – expires 6/16/2024. Asbestos record, 11/29/2022 Asbestos manifest shipment record 11/29/2022 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 22 of 22 MSW waste screening form 7. Corrective measures are necessary as result of this inspection. A follow up inspection will be conducted by Solid Waste Section Staff in about 60 days from inspection sent date. 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: 12/21/2022 X Email Hand delivery US Mail Certified No. [ _] Copies: Jason Watkins, Field Operations Branch Head Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Head – 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