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Home My WebLink About7803-MSWLF-1997_INSP_20240104FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 10 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: January 4, 2024 Date of Last Inspection: September 28, 2023 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 Gene Walters, Robeson County Solid Waste 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) - UNRESOLVED 2. 15A NCAC 13B .1626 (11) – UNRESOLVED 3. 15A NCAC 13B .1626 (8)(a) – UNRESOLVED 4. 15A NCAC 13B .1626 (8)(b) – UNRESOLVED FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 10 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. 2. 15A NCAC 13B .1626 (8) Drainage control and water protection requirements. (c) Solid waste shall not be disposed of in water. 3. 15A NCAC 13B .1626 (2) Compaction and cover material requirements. Solid waste shall be managed within the disposal area throughout the life-of-site and post-closure care period to prevent the escape of waste and the attraction of vectors and scavenging, and to minimize fires and the generation of odors. The owner or operator shall comply with this requirement using the following compaction and cover procedures: (b) Except as provided in Sub-Item (c) of this Item, the owners or operators of 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. 4. 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. Upon follow up inspection for previous violations, additional violations were discovered around phase 5, near the working face and along where phase 5 ties into phase 6. Severe erosion and insufficient cover along the EOW of the NW corner of Phase 5 resulted in soil/sediment and exposed waste beyond the limits of disposal. If water comingles with waste, then it is considered leachate and not allowed to discharge or go beyond the leachate collection system. Although no leachate runoff was observed during inspection, conditions onsite may allow for such a discharge and should be addressed so that they cannot. Upon observation, Mr. Powell spoke with Mr. Walters to alert him to the situation and asked that corrective actions in this area be made a priority. Mr. Walters asked the location of the issue and began to work immediately by contacting staff and agreed to send photos by the beginning of the following week to show that the area was properly addressed. No photos or communication on the corrective actions were received by Mr. Powell as agreed. In addition, a large amount of waste was observed in the water, now leachate, ponding across entire phase 6. Waste has eroded and wind blown into phase 6, which has been mentioned before but has continued and allowed to accumulate. Severe erosion in and around the higher elevations of Phase 6 has damaged the rain cover and potentially the liner. Due to the ongoing erosion issues at the edge of Phase 6, it may be necessary to evaluate the integrity of the liner in the impacted area to determine if it still meets design specifications before any fill operation begin. All water in phase 6 was being treated as leachate, however, the pump that was removing all ponded leachate in phase 6 back to leachate collection system has been down and will be down until parts arrive in a few weeks according to Mr. Walters. Facility staff should look into additional resources in the event of equipment failure and include it as part of their contingency plan. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 10 Photo depicts phase 5 from a distance looking at NW corner. Severe erosion along entire phase 5 north side, with waste and sediment beyond EOW/Liner. North side of Phase 5. Sediment eroded beyond EOW/Liner with leachate ponding. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 10 Close up of previous photo. Looking east along northside of Phase 5. EOW markers are white PVC pipes. Photo depicts waste and cover sediment beyond liner/EOW, exposed waste and now windblown waste. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 10 Close up view of previosu photo. Photo taken on NW corner where phases 5 and 6 meet, also access road to current working face of phase 5. In photo, on left. is phase 5 and access road to working face. In the center is severely eroded area into phase 6, with much windblown and exposed waste, with waste floating in leachate pond that extends across the entire phase. The liner/cover is eroded and not visible any longer on the east end of the phase. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 10 This photo is the same as previous, but view is slightly west so what’s left of the edge of liner/cover is visible. Photo shows the rest of the phase 6 that wasn’t shown in previous two photos. Per the facility staff, all water is being treated as leachate and pumped back to leachate collection system but not currently. Robeson County is waiting for parts for the pump. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 7 of 10 Closeup view of erosion, exposed waste, windblown waste, and waste floating in phase 6. ADDITIONAL COMMENTS 1. The purpose of this visit was to do a follow-up inspection of the Robeson County Landfills and corrective actions previously identified. Previous violations are still occurring, and new violations noted. 2. Mr. Powell didn’t visit the working face during this inspection due to road conditions up to working face and recent rainfall. Signage previously noted at MSW, that was added as requested, is no longer installed. Please install the required signage and maintain. 3. Windblown pickup along the road of the NW corner of MSW was being done during this scheduled inspection. 4. Mowing the entire landfill has been noted as being needed in recent inspections. However, the MSWLF still needs to be mowed across much of the landfill. 5. Some erosion rills need addressing alongside slopes of MSW. Eroded areas should be repaired as soon as practical once observed. 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 10 6. Mr. Walters and Mr. Powell discussed the findings while onsite. Mr. Walters explained the landfill had some new staff to haul soil and they have been addressing cover but still needs work. Solutions were discussed along with the counties continued effort to find contractors. West end of MSWLF. Need mowing. East side MSWLF. Needs mowing. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 9 of 10 North side MSWLF. Some areas need mowing. Southside of MSWLF FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 10 of 10 7. 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. Corrective measures are necessary as result of this inspection. A follow up compliance inspection will be conducted by Solid Waste Section Staff within about 60 days’ receipt of this inspection report. 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: 2/9/2024 X Email Hand delivery US Mail Certified No. [ _] Copies: Andrew Hammonds, Eastern District Supervisor - Solid Waste Section Sherri Stanley, Permitting Branch Head – Solid Waste Section Elizabeth Werner, Hydrogeologist – Solid Waste Section Kristina Locklear-Cummings, Robeson County Solid Waste Kellie Blue, County Manager, Robeson County