3424_INSP_20180424

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 9

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: April 24, 2018 Date of Last Inspection: March 2, 2018

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: [phone] or 215-962-0353 (mobile)
Email address: [e-mail]

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:
Partial 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.”

Discussions are underway between Ming-Tai Chao, Permit Engineer, Solid Waste Section, and representatives
of Abbey Green concerning site design and capital improvements to expand the current leachate collection
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 9

system and enable effective separation of storm water and leachate. Interim measures to minimize leachate
escaping the collection system have been put into place, as agreed to October 31, 2017. This inspection took
place during a light, steady rain. The path of the leachate from the loading deck/ramp area was clearly visible.
Stormwater (likely comingled with leachate) could be seen bypassing the leachate collection system, proceeding
along the eastern edge of the covered tipping floor, then turning west along the northern end of the tipping floor
into the stormwater collection system.

In addition, a pile of waste was observed on the loading deck and ramp adjacent to the conveyor that feeds the
picking line. Mr. Cosgriff stated that his early shift equipment operator had moved waste to this location at 7
am, when daily operations began. He confirmed that rain had been falling at that time and had continued up to
the present time. Waste may not be deposited on the ground during rain events. Ensure that waste is
moved from the covered tipping floor directly onto the conveyor; and, that any waste that falls from or
escapes the conveyor is collected and removed to the covered tipping floor or a leak-resistant container
immediately.

Potential leachate seen flowing past the
covered tipping floor (above) and turning
northwest into the storm water collection
system (left). Note that waste is exceeding
the limits of the covered tipping floor on
both the eastern and northern sides.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 3 of 9

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.”
Windblown litter, wet from the rain, was observed inside the fence line in all operations areas, including the
scale house; the trailer loading /parking area and adjacent storage bunkers; under and around the covered
View of the ramp and loading
deck from the south side. The
conveyor that feeds the picking
line can be seen to the right of
the loading deck.
View of the loading deck from
the north side. The southeast
corner of the covered tipping
floor is visible on the right, and
the picking line is visible on the
left.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 9

picking line; on and around the trommel and the conveyor structure that feeds the picking line; along the entire
fence line; in the grassy areas along the fence line west of the employee parking lot; and, mixed with fines
covering the gravel operations area between the covered picking line and the employee parking lot. Mr. Baker
stated that staff concentrate on collecting windblown waste outside of the fence line at the end of each day’s
operations. All windblown litter must be collected at the end of each operating day and stored in a
covered, leak-resistant Following some discussion, Mr. Baker stated that additional staff may be required to
accomplish this task daily.

Views of the operations area, from the covered picking line (above right) to the trailer loading area (below left). Note the
amount of windblown litter and accumulation of waste in these areas.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 9

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 was not observed during this inspection. Ongoing discussion is taking place between facility
staff and the Solid Waste Section to address the issues relating to the South Site.

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.

Neither the North Site nor the Leased Site were not observed during this inspection. Ongoing discussion is
taking place between facility staff and the Solid Waste Section to address these issues.

OBSERVED VIOLATIONS:
The items described within the STATUS OF PAST NOTED VIOLATIONS above, were observed during this inspection.
These are new and/or continuing violations until they are resolved.

ADDITIONAL COMMENTS:

1. This inspection took place as a result of a report from the Forsyth County Office of Environmental Assistance
and Protection stating that a staff member had driven by to observe the facility, based on a noticeable increase
in the number of demolition permits listing Abbey Green as the disposal facility. The staff member had
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

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observed large piles of C&D waste in the area around the covered tipping floor, and that the tipping floor itself
was full of waste.
2. Only the primary C&D operations area was inspected, including the covered tipping floor, the covered picking
line and the areas surrounding them.
3. The inspection took place during light rain and drizzle, and began at approximately 7:30 am, about 30 minutes
after the start of daily operations at the facility.
4. The covered tipping floor contained two large piles of waste. Mr. Baker indicated that one pile would be run
through the picking line and the other would be loaded up and trucked to the landfill for disposal. Waste was
observed exceeding the limits of the tipping floor, outside the drip line of the structure on both the eastern and
northern sides.
5. No large piles of C&D waste were observed in the operations areas, as had been described in the Forsyth
County report.
6. At the time of this inspection, the picking line was not operating. Mr. Cosgriff explained that a bearing was
being replaced, and that daily operations would commence once that process had been completed.
7. Waste was observed on the loading deck and ramp, waiting to be fed up the conveyor to the picking line. Mr.
Cosgriff stated that the waste had been loaded into this area at 7 am when operations began for the day. (See the
Status of Past Noted Violations section of this report for additional information.)
8. The loading deck and ramp are constructed of “crusher run,” a material that Mr. Baker described as crushed
clean inerts. Through constant use, the crusher run material has become contaminated with waste. Ensure that
the crusher run is removed from the loading deck and ramp area periodically and disposed of properly,
so that waste is not allowed to accumulate in this area.

A view of the loading ramp from behind the conveyor on the east side. Note the waste that has mixed into and
contaminated the crusher run that was used to construct the ramp and the loading deck.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 7 of 9

9. The path of the stormwater (likely comingled with leachate) from the loading deck/ramp area was clearly
visible. It could be seen bypassing the leachate collection system, proceeding along the eastern edge of the
covered tipping floor, then turning west along the northern end of the tipping floor into the stormwater
collection system.
10. The entire operations area, in and around the covered tipping floor and picking line, was replete with
windblown litter. Fence lines and wind screening had pieces of waste stuck into them, and the grassy areas (See
Status of Past Noted Violations section of this report for additional information.)
11. The LCID landfill/inert debris stockpile area was inspected. The tipping area for inert debris is located on the
top of the LCID unit, and material was found to be spread out, with ponding water in and around the piles.
Unacceptable material was observed through the material in this area, including plastics, metal and fiber.
Ensure that all unacceptable material is removed from the inert debris stockpile immediately and that
waste is removed from incoming loads and disposed of properly as the loads are received. Contaminated
loads of inerts, if they are accepted at the facility, must be stored on the covered tipping floor until the
unacceptable materials are removed and disposed of properly.

A view of the ramp from the
loading deck. Note the
degree to which the crusher
run has been contaminated
by waste.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 8 of 9

View of the eastern edge of the inert debris piled in the tipping area (atop the LCID landfill) with unacceptable materials
throughout and ponding water in the foreground.
Unacceptable materials can be
clearly seen mixed into the
inert debris in the tipping area.
Note ponding water in the
foreground.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 9 of 9

12. Mr. Baker led the way to the sediment pond, located to the north of the main operations area and scale house.
He added that he is required to inspect the pond and submit a report after every .10” or greater rain event. Mr.
Baker explained that the facility had received approximately 3” of rain during the latest rain event, and that the
pond was functioning properly, filtering the liquid as it passes through the forebay and in the boggy area along
the north side of the main pond, as designed. The pond appeared to be well-maintained. Some windblown litter
was visible in the forebay of the pond and in the grassy area on the northern bank. Mr. Baker stated that this
material had accumulated since the close of operations the previous day.

Please contact me if you have any questions or concerns regarding this inspection report.

________________________________________ Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative

Sent on: April 27, 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