HomeMy WebLinkAbout3424_INSP_20180302FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 1 of 11
UNIT TYPE:
Lined
MSWLF LCID X YW Transfer X Compost SLAS COUNTY: Forsyth
Closed
MSWLF HHW White
goods Incin T&P X FIRM PERMIT NO.: 3424 + N1044
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE
Date of Site Inspection: March 2, 2018 Date of Last Inspection: April 4, 2017
FACILITY NAME AND ADDRESS:
Abbey Green, Inc. and Overdale Holdings, Inc.
Transfer, Recycle, Resource Recovery and Processing Facility
5030 Overdale Road
Winston-Salem, NC 27107
GPS COORDINATES: N: 36.032167° W: -80.233250
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Randall Baker, General Manager
Telephone: 336-785-2130 or 215-962-0353 (mobile)
Email address: rbaker@abbeygreen.com
FACILITY CONTACT ADDRESS:
Abbey Green, Inc.
5030 Overdale Road
Winston-Salem, NC 27107
PARTICIPANTS:
Randall Baker, General Manager – Abbey Green, Inc.
Joseph Cosgriff, Operations Manager – Abbey Green, Inc.
Susan Heim, Environmental Senior Specialist – Solid Waste Section
STATUS OF PERMIT:
LCID Landfill Notification recorded in Forsyth County November 24, 2009
Permit to Construct/Permit to Operate issued July 30, 2010
Revised Permit to Construct/Permit to Operate issued November 2, 2010
Permit to Operate – Modification issued April 27, 2011
Permit to Operate – Modification issued November 9, 2011
Current Permit to Operate issued April 13, 2016
Permit to Operate expires July 30, 2025
PURPOSE OF SITE VISIT:
Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS:
1. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0302(3) states: “Water that comes into contact
with solid waste will be contained on-site or properly treated prior to discharge from the site.”
Capital improvements are planned for future construction that will expand the current leachate collection system
to enable the effective management all leachate produced at the facility. Interim measures, agreed to October
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 11
31, 2017 to be in effect for a period not to exceed 18 months, have been put into place that include a temporary
concrete jersey wall, designed to direct surface water away from waste under and around the picking line,
placed on the northeast end of the picking line. Mr. Baker stated that the agreed upon revised operating
procedures for managing waste during normal operations and during rain and other weather events had been
adopted. Because the facility was not operating during this inspection, these changes were not able to be
observed. To date, no design changes for the trench drain, located on the west side of the covered tipping floor,
have been submitted to Permit Engineer Ming Chao, as required.
Within 10 days of receipt of this inspection report, contact Permit Engineer Ming Chao to discuss and
review the effectiveness of the trench drain as a temporary means of leachate collection and management.
Temporary jersey wall installed at the NE end of the picking line to help separate storm water from waste.
Trench drain covered with crusher run and filled with
dirt and debris.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 11
2. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0203(d) states: “By receiving solid waste at a
permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall
comply with the conditions of the permit.” Permit to Operate No. 3424, Attachment 3, PART VI: Transfer
Station/Treatment & Processing Unit permit condition 20.e.ii. states, “Windblown materials must be collected
by the end of the day and no windblown material may be allowed to leave the facility boundary.”
The facility appeared to be relatively clear of windblown litter during this inspection. The sides of Overdale
Road from the gate to the South Site is one exception. In this area, windblown litter was ensnared in the
roadside vegetation. Another exception is the area across the roadway from the truck entrance to the facility,
where the fence surrounding the Overdale Road Transfer Station is located. Sections of fencing had been
installed at the edge of the paved roadway (on the transfer station side) to catch windblown litter that leaves the
facility and becomes an issue for the transfer station. Windblown litter was caught in these fencing sections, and
Mr. Baker stated that waste is collected from this area at the end of every operating day.
3. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0201(c) states, in part: “No solid waste
management facility shall be established, operated, maintained, constructed, expanded, or modified without a
currently valid permit issued by the Division for the specified type of disposal activity.”
The South Site remains an area where waste is stockpiled, pending analysis of the material and a determination
about proper management is made by the Section. Following the inspection, Mr. Baker provided a report on
test results from samples of the South Site material to the Solid Waste Section for review. A response will be
provided under separate cover when the review is completed.
Windblown litter beside the access road to the South Site.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 4 of 11
4. CORRECTIVE MEASURES IN PROGRESS: 15A NCAC 13B .0203(d) states: “By receiving solid waste at a
permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall
comply with the conditions of the permit.” Permit to Operate No. 3424, ATTACHMENT 1, PART I:
GENERAL PERMIT, general permit condition 6 states, in part, “Operation of this solid waste management
facility shall be in accordance with the 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.” Permit to Operate No. 3424, ATTACHMENT 1, PART VI, TRANSFER
STATION/TREATMENT & PROCESSING UNIT(S), List of Documents for Approved Plan, includes the
Operations Manual, December 31, 2015 (DIN 25646). Section 2.8 of the approved Operations Manual
(December 31, 2015), Processing Area Legend, indicates that the preferred location for aging trommel-overs is
the South Site.
Please see comments for Violation #3 above.
5. 15A NCAC 13B .0203(d) states: “By receiving solid waste at a permitted facility, the permittee(s) shall be
considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.”
Permit to Operate No. 3424, ATTACHMENT 1, PART I: GENERAL PERMIT, general permit condition 6
states, in part, “Operation of this solid waste management facility shall be in accordance with the 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.” Permit to Operate
No. 3424, ATTACHMENT 1, PART VI, TRANSFER STATION/TREATMENT & PROCESSING UNIT(S),
List of Documents for Approved Plan, includes the Operations Manual, December 31, 2015 (DIN 25646).
Section 2.8 of the approved Operations Manual (December 31, 2015), Processing Area Legend, indicates that
the Leased Area will be used only for mixing and curing and product storage.
Based on observations and discussions after the April 2017 inspection, a wood waste management proposal was
submitted to the Section, which included plans for removal of all engineered, painted and/or coated wood waste
from the leased site. Some unacceptable materials were found on the Leased Site during this inspection,
A view of the South Site from
the access roadway.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 5 of 11
including shingles, plywood, plastic strapping and film, and metal. Mr. Baker stated that the wood waste pile is
generated from the picking line, where these contaminants should be separated before the wood is moved to the
Leased Site. Enhanced screening procedures at the picking line should be implemented to reduce unacceptable
materials being moved to areas of the site not approved for their management. Further, per your June 23,
2017 letter to the Section, only one grinding cycle would occur on the leased site to reduce existing volume
and then wood waste operations would return to the North site until such a time that the leased site was
approved for use. To date, that authorization has not occurred and, therefore, regular wood waste
operations shall only be undertaken in approved areas.
Mixed waste can be
seen in the wood waste
piles on the Leased
Site.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 6 of 11
OBSERVED VIOLATIONS:
None.
ADDITIONAL COMMENTS:
1. This inspection took place on a Friday under very windy conditions. The facility was not operating, and Mr.
Baker explained that half of every Friday is spent on facility and equipment maintenance. He added that, due to
the continuing high winds, operations would not resume.
2. The facility is permitted to conduct C&D treatment and processing operations and solid waste transfer
operations. In addition, a notified LCID (N1044) is located on the site.
Records Review:
3. Tonnage records were reviewed for the period April 1, 2017 through February 28, 2018. For the 4th quarter of
FY 2016-17, the facility accepted a total of 19,870.42 tons of waste, 1,562.35 tons of which was transferred out
for disposal or recycling elsewhere. During the 1st quarter of FY 2017-18. 16,793.60 tons of waste was
accepted; 10,133.65 tons of waste was accepted during the 2nd quarter of FY 2017-18; and, 5,503.87 tons of
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.
Processed and
unprocessed wood
waste in the grinding
area on the Leased Site.
Note unacceptable
materials present,
including a plastic
bucket (lower right)
and plastic and
cardboard visible
throughout the
unprocessed pile.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 7 of 11
waste was accepted during January and February of 2018.
4. Waste screening records for the current fiscal year were reviewed. The frequency of the screenings was more
than ample to meet requirements. A new waste screening form had been put into use to better delineate the
make-up of loads, and records were filed in order by date in a notebook used exclusively for that purpose. A
misunderstanding about the information required in the portion of the form dealing with rejected material led to
some forms being incorrectly filled out. Please ensure that unacceptable waste is properly noted on waste
screening forms, including the disposition of that unacceptable waste.
5. The facility provides safety training for staff in the form of monthly safety meetings that focus on various
aspects of facility operations and equipment use and OSHA standards. Records of these meetings are kept using
employee sign-in sheets, which were reviewed for the current fiscal year.
6. A review of the required training certifications revealed the following NCSWANA certified staff:
• Joseph Cosgriff – Certified Transfer Station Operations Specialist – Certificate # TS-2017041 – expires
9/7/2020;
• Heather Varner – Certified Transfer Station Operations Specialist – Certificate # TS-2017008 – expires
3/23/2020.
The required training certification for this facility is the Certified Transfer Station Operations Specialist.
Additionally, Mr. Baker has been certified as a Landfill Operations Specialist (Certificate # LF-2017011 –
expires 3/10/2020).
Facility Inspection:
7. At the time of this inspection, the facility was not operating and facility staff were performing maintenance
duties. Mr. Baker explained that the facility would not re-open on this day due to high winds.
8. For the most part, the facility appeared to be free from windblown litter. Fence lines and wind screening were
clean. However, windblown material had accumulated along the roadways. (See Status of Past Noted Violations
section of this report for additional information.)
9. The facility is protected by a chain link fence along the road frontage. A locking gate secures the scale house
entry point, and an additional locking gate secures the entrance to the South Site and LCID/inert debris
operations area.
10. Facility access roads are of all-weather construction and maintained in good condition.
11. The facility operates under erosion control permits issued by Forsyth County and, according to Mr. Baker, the
county inspector visits regularly to ensure compliance.
12. A new outgoing scale was being installed at the time of this inspection. Mr. Baker explained that the state now
requires external visible scale indicators, and both the incoming and outgoing scales would be in compliance
with the new requirement.
13. Although the facility had not been operating on the day of this inspection, waste was piled on the loading deck
next to the picking line, and some waste could also be seen on the conveyor that feeds the picking line. Mr.
Baker stated that all of this waste would either be moved onto the covered tipping floor or placed into covered
containers before the end of the operating day.
14. The ramp leading to the loading deck is constructed of crushed inerts (“crusher run”). Waste was observed to be
mixed into the ramp. Ensure that waste is collected from the loading deck and ramp and returned to the
covered tipping floor prior to the end of every operating day.
15. The leachate collection system consists of a trench drain, located along the western edge of the covered tipping
floor, a temporary jersey wall, and sloping concrete pads that help separate storm water flow from leachate.
16. Plans for updating the leachate collection system are currently being developed. Temporary leachate
management procedures are in effect for a maximum of 18 months from the approval date of October 31, 2017,
by which time an approved permanent leachate management system must be in place.
17. The trench drain was inspected and found to be filled with muck and waste. No grates are currently installed
over the drain. Instead, steel and wood plates cover the drain. Mr. Baker explained that the drain doesn’t
function as originally designed, and that the drain pipe that carries the leachate is located under the muck inside
a steel box that protects it from the solids that become trapped. He added that some success had been achieved
with moving the liquid along the top of the trench drain by adding a layer of crusher run over the top plate. The
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 8 of 11
temporary leachate collection system must be approved by the Permit Engineer. (See Status of Past Noted
Violations section of this report for additional information.)
18. The tipping floor held two separate piles of waste, both of which were contained under the roof; no waste from
these piles had extended beyond the roofline. Mr. Baker indicated that one pile had a low percentage of
recoverable material and would be loaded directly into a transfer trailer for disposal at A-1 Sandrock (Permit
#4117). He stated that the other pile would be hand sorted then sent through the picking line when operations
resumed the following Monday.
19. The area of the tipping floor that was visible appeared to be in good condition. No major cracks or missing
areas of concrete were noted.
20. The picking line was not in use during the inspection. Some waste was observed in and around the container
stalls located under the picking line, and also on the operations floor at the north end of the picking line. Mr.
Baker stated that this waste would be collected and disposed of properly before the end of the working day.
21. The LCID landfill/inert debris stockpile area was inspected. The edge of waste markers that had been installed
previously were found to be in place and intact. The tipping area is located on the top of the LCID unit.
Incoming trucks tip their loads and then equipment operators spread the waste to check for unacceptable
materials before pushing it over into the stockpile area. The stockpile area appeared to be neat and well-
managed. However, some unacceptable material was observed, including painted concrete, metal and plastics.
Ensure that all unacceptable material is removed from the inert debris stockpile and disposed of
properly; and, that facility personnel are adequately trained to be effective at recognizing and separating
unacceptable material before pushing the load into the stockpile.
22. A stockpile of “crusher run,” the term used by Mr. Baker to describe crushed mixed inerts, was located to the
north of the unprocessed inert debris collection area.
23. A stockpile of processed gypsum was covered with tarps and staged to the west of the crusher run. Please
ensure that tarps are inspected regularly to confirm they are intact, in place and properly secured.
24. Progress had been made in reducing the legacy trommel-overs stockpile on the South Site since the previous
inspection on April 4, 2017. However, Mr. Baker stated that, because material was not permitted to leave the
site, operating room had been greatly reduced. He explained that new material brought to the South Site daily is
being screened as it arrives, weather permitting, and stored separately from the processed legacy pile. He added
that the unprocessed legacy stockpile has not been worked regularly due to the weather and to the continued
processing of the new trommel-overs that result from daily operations. Mr. Baker concluded by stating that he
estimates, with good weather and permission to move material from the South Site, the legacy stockpile could
be processed and removed within a 90-day window.
25. The sediment pond, located to the north of the main operations area and scale house and into which stormwater
from the main operations area is directed, appeared to be clean and well-maintained. No windblown litter was
observed in this area. Mr. Baker stated that additional maintenance would be performed to remove small trees
from the south bank of the pond as the weather improves this spring.
26. The North Site had been cleared of processed and clean unprocessed wood waste and rutted areas had been
repaired to prevent ponding water on the site. A large pile of engineered wood waste was observed near the
southern edge of the site. The pile was accessible from all sides. It is recommended that at least one fire
break be made in the engineered wood waste pile to allow better access in case of emergency.
27. The slope of the beneficial fill that makes up the southern portion of the North Site had been cleared of wood
waste; however, the slope had not yet been seeded. Ensure that a stable vegetative cover is established on
the beneficial fill slopes of the North Site.
28. Maintenance had been performed on the area between the North Site and the Leased Site, removing windblown
litter and unacceptable wastes that had been observed during previous inspections. A roll-off container used for
the temporary storage of scrap tires was observed to be covered with a watertight tarp. Empty roll-off containers
were stored in this area as well.
29. To a large extent, the Leased Site has been constructed of beneficial fill. Mr. Baker explained that the facility
currently has three beneficial fill areas that have been approved as part of the facility erosion control plan and
permits: the North Site, the Leased Site and the LCID/inert debris area. Initial seeding of the side slopes did not
appear to be successful, and some signs of erosion were becoming apparent. Ensure that repairs are made to
the side slopes of the beneficial fill and that a stable vegetative cover is established.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 9 of 11
30. What appeared to be painted concrete was observed in the southeastern slope of the beneficial fill area of the
Leased Site. Mr. Cosgriff stated that these slabs of concrete had been covered with mortar that gave the surfaces
a different color that might appear to be paint. Ensure that any unacceptable material is removed from the
beneficial fill area of the Leased Site.
31. The southern section of the Leased Site is being used for grinding operations and is covered in wood mulch, as
is the southern slope of the beneficial fill. A large tub grinder is staged on the site and operates daily, weather
permitting. Mr. Baker explained that any unacceptable materials are separated as the wood waste is processed.
Processed wood waste/mulch is not an approved alternative for soil cover over beneficial fill; and, in no
case is mulch permitted to be mixed with or added to a beneficial fill. It is acknowledged that mulch may
be usable in conjunction with your county-approved erosion control plan under the guidance of your
county inspector. (See the photo below and the comments under violation #5 in the Status of Past Noted
Violations section of this report for additional information regarding continued use of the leased site.)
32. The Leased Site was found to contain piles of “scalpings” from Ingredion’s neighboring facility that Abbey
Green grinds along with its clean wood waste. In addition, a large pile of lumber was stockpiled for grinding.
Mr. Baker stated that the lumber had been gleaned from the picking floor operations and is moved to the Leased
Site as it accumulates. Unacceptable materials, including shingles, engineered lumber, plastic strapping and
film, and metal, were found in the unprocessed wood waste stockpiles. Ensure that all unacceptable materials
are collected and removed from wood waste prior to storage at any location on the facility footprint, and
that all unacceptable materials currently found on the Leased Site are removed immediately. (See Status
of Past Noted Violations section of this report for additional information.)
A view of the southeast slope of the beneficial area on the Leased Site with mulch covering the inert
debris.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 10 of 11
A view of the
southwest slope of
the beneficial fill
area on the Leased
Site shows scant
vegetative cover and
the beginning of
erosion rills.
Matting can be seen
at the bottom of the
slope (right
foreground) where it
had been damaged
and rolled back by
wind and rain.
A view of the operations area with the picking line (left) and the covered tipping floor (right), and the loading deck in between.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 11 of 11
Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: 336-776-9672
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: March 13, 2018 to
Randall Baker.
X Email Hand delivery US Mail Certified No. [ _]
Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section
Deb Aja, Eastern/Western District Supervisor – Solid Waste Section
Ervin Lane, Hydrogeologist – Solid Waste Section
Ming-Tai Chao, Permitting Engineer – Solid Waste Section