HomeMy WebLinkAbout7803_RobesonMSW_AssessmentAndCorrectiveActionLetter_DIN28195_20170714
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July 14, 2017
Sent Via Email – harrell.walters@co.robeson.nc.us
Mr. Gene Walters
Solid Waste Director
Robeson County Solid Waste Department
246 Landfill Road
St. Pauls, North Carolina 28384
Re: Assessment Monitoring and Groundwater Corrective Action
Robeson County MSW Landfill
7803‐MSWLF‐1997
DIN 28195
Dear Mr. Walters:
It has come to the attention of the Solid Waste Section (Section) that the assessment
monitoring program and groundwater corrective action program at the Robeson County landfill
have not been implemented as designed and approved. For the assessment monitoring
program, the facility has failed to implement Appendix II monitoring in the assessment
monitoring wells during each first semi‐annual sampling event in accordance with the August
2014 Water Quality Monitoring Plan (DIN 22092) and 15A NCAC 13B .1634. For the
groundwater corrective action program, the facility has failed to implement groundwater
corrective action by not conducting the required MNA performance parameters and by not
submitting a monitored natural attention (MNA) screening model annually in accordance with
the County’s approved June 2008 Preliminary Corrective Action Plan (DIN 9625), the June 10,
2015 Permit to Operate (DIN 24454), 15A NCAC 13B .1636, 15A NCAC 13B .1637, and 15A NCAC
2L.
Robeson County must take all necessary steps to ensure the protection of public health and the
environment. In order to come into compliance with the assessment monitoring program, the
facility shall monitor for Appendix II constituents in the assessment monitoring wells during the
second semi‐annual sampling event of 2017 and follow this revised assessment monitoring
schedule going forward in accordance with the approved August 2014 Water Quality
Monitoring Plan. To come into compliance with the groundwater corrective action program,
the facility shall submit a Corrective Action Plan Addendum within 30 days of receipt of this
letter. Since Robeson County discontinued the implementation of the approved selected
remedy of enhanced bioremediation at the facility with an approval from the Section on
December 9, 2014 (DIN 22453) after a review of the Corrective Action Evaluation Report (CAER)
dated August 25, 2013 (DIN 19945), a Corrective Action Plan Addendum is required to be
submitted for Section approval. The Addendum shall include the implementation of the new
selected remedy of MNA with landfill gas recovery and shall include monitoring of all the MNA
performance parameters, conducting the MNA screening model, and quantitatively determine
the effectiveness of the landfill gas recovery system.
If Robeson County does not submit a Corrective Action Plan Addendum and does not conduct
Appendix II monitoring, Robeson County may be entered into Tiered Enforcement to achieve
compliance with penalties up to $15,000 per day 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 and may also be subject to other enforcement actions including injunction from
operation and any such further relief.
If you have any questions, please do not hesitate to contact me via email
elizabeth.werner@ncdenr.gov or phone (919) 707‐8253.
Sincerely,
Elizabeth S. Werner
Permitting Hydrogeologist
Solid Waste Section
Cc via email: Cody Hunt, Hunt Environmental
Ethan Caldwell, PE, PG – SWS, Permitting Engineer
Amanda Freeman – SWS, Environmental Specialist
Drew Hammonds – SWS, Field Operations Eastern Supervisor
Jason Watkins – SWS, Field Operations Branch Head
Ed Mussler, PE – SWS, Permitting Branch Head