3424_INSP_20190131

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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
X
Compost
SLAS
COUNTY: Forsyth
MSWLF
PERMIT NO.: 3424-TRANSFER-2010
Closed
xxW
White
Incin
T&P
X
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P/
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: January 31, 2019 Date of Last Inspection: April 24, 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: Roger Nielsen
Telephone: [phone] (office); [phone] (mobile).
Email address: RSN(kabbeycolor.com
FACILITY CONTACT ADDRESS:
P. O. Box 12339
Winston-Salem, NC 27117
PARTICIPANTS:
Roger Nielsen — Abbey Green
Joseph Cosgriff, Operations Manager — Abbey Green
Jason Watkins, Field Operations Branch Head — Solid Waste Section
Chuck Kirchner, Environmental Senior Specialist — Solid Waste Section
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; a 5-year limited review of the permit is required by July 30, 2020 and
must be requested by the permittee on or before January 30, 2020.
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."
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FACILITY COMPLIANCE INSPECTION REPORT
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NIF Solid Waste Section
Significant progress has been made in separating storm water from leachate since the last inspection on April
24, 2018:
• The original path of the stormwater, from the base of the bank east of the employee parking area to the
internal access roadway that connects to the gravel section of Overdale Road, is being re-established.
Mr. Cosgriff pointed out the defined line where the toe of the bank meets the surface of the gravel
operations area. He explained that the edge of the operations area slopes toward the bank, so that the
surface water moves away from the operations area and does not come into contact with waste. Mr.
Cosgriff stated that he hoped to have this measure completed and fully functional by spring. Please see
the note in the inert debris section of the comments regarding the reintroduction of this stormwater into
the ditch line at the toe of the debris storage piles.
• The trench drain, located on the western edge of the covered tipping floor, had been partially opened for
a length of approximately 20' beginning at the drain that enters the sanitary sewer line. This portion of
the trench drain was observed to have liquid running through it. Additional information is needed about
the leachate collection system in order to review and approve the final design and function.
• The loading ramp, constructed of crusher run and located between the south end of the covered tipping
floor and the picking line conveyor, had been completely removed. Mr. Cosgriff explained that
removing the ramp allowed the area to be maintained throughout the operating day. He further stated
that the ramp itself had accumulated waste that became trapped and mixed with the crusher run as
operations occurred. Because the ramp was not covered, all waste that had been contained in the ramp
was exposed to the elements, and thus continually produced leachate. Removal of the ramp has resolved
this issue. However, if waste in this area does come into contact with water due to a sudden rain event,
the interim procedures that had been put into place requiring leachate to be pushed from this area onto
the covered tipping floor, thus directing it to the leachate collection system through the trench drain,
must be followed.
• A pre-sorting line had been purchased and brought to the site. Mr. Cosgriff stated that the new line
would be positioned next to the south end of the covered tipping floor, so that waste could be fed
directly onto the conveyor. He explained that the pre-sort line would then be joined to a conveyor that
would feed the picking line so that the pre-screened waste could move directly into the next phase of
processing. Mr. Cosgriff stated that the plans include ultimately covering everything from the pre-sort
line up to the picking line conveyor system. This would drastically reduce the amount of leachate
produced in this area of the operation.
The new pre-sort line ready to be
positioned next to the covered
tipping area. (Photo taken by J.
Watkins 1-31-19.)
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Solid Waste Section
li t
Y
At left, a view of the open area of the trench drain
near the northwest edge of the covered tipping floor.
(Photo taken by J. Watkins 1-31-19.)
7MMMMM Below, a view looking north between the picking line
on the right and the covered tipping floor on the right.
This area had formerly been occupied by the loading
ramp. The area now appears to be clean and well -
maintained. (Photo taken by S. Heim 1-3-19.)
2. RESOLVED: 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."
During this inspection, the facility was found to be clean and windblown litter well -managed. No accumulation
of waste was observed along the fence lines, in the vegetation, in the stormwater measure, or in the operations
area in general. Mr. Cosgriff stated that new daily operating procedures had been adopted that allow an hour at
the end of every operating day to clean up, including the collection of windblown trash.
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
A view of the operations area behind the picking line. The
_.• 25' windscreen, bank and employee parking area can be
seen at the top right. (Photo taken by S. Heim 1131119.)
Right. A view looking east toward the
employee parking area and office. The
operating area north of the picking line is
clean, as is the bank, the fence line and the
wind screen. (Photo taken by S. Heim 1131119.)
s
I + Left. A view looking south along the eastern
'' ►., edge of the covered tipping floor. Note that all
j . waste is contained under the drip edge. (Photo
taken by S. Heim 1131119.)
� r
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A view of the
western portion of
the operating area
north of the
covered tipping
floor. The loading
area is clean, and
no windblown trash
is evident along the
retaining walls or
the fence line.
(Photo taken by S.
Heim 1131119.)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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."
Discussions between facility staff and the Solid Waste Section concerning use of the South Site for the storage
of processed waste and additional screening operations, as well as the status/disposition of the material
produced on the South Site, are ongoing. At the time of this inspection, the "legacy" trommel-overs stored on
the South Site, from the roadway into the site approximately 120', had been screened and moved to a previously
unused area to the south of the original stockpile. Mr. Cosgriff estimated that so far 1/4 to 1/3 of the stockpile
had been screened, citing a series of storm events over the past six months as a significant limiting factor. He
also stated that the material from the South Site will ultimately be mixed with processed wood waste to form a
soil amendment that would be offered for sale. He further explained that additional screening has resulted in a
much finer material that meets the criteria set forth in the Operations Manual and contains mainly wood,
cellulose materials and inerts.
South Site from
itrance. The
kpile of "legacy"
can be seen
!s of re processed
foreground. The
ripment is located
rth of the
rto taken by J.
19.)
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FACILITY COMPLIANCE INSPECTION REPORT
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NIF Solid Waste Section
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.
As it pertains to new material going to the south site, Mr. Cosgrove stated that additional screening has already
resulted in a much finer material that meets the criteria set forth in the Operations Manual and contains mainly
wood, cellulose materials and inerts. The Section will continue to monitor the changes being implemented with
the new pre-screening process to ensure those changes adequately address previous concerns though initial
indications are promising. Additional information about the new process and the finer material being produced
may be requested to make a final determination about the status of this material.
RESOLVED: 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.
The Leased Area continues to be used for wood waste storage and processing operations. Mr. Cosgriff stated
that changes in the operating procedures will result in cleaner wood waste reaching the area. Some unacceptable
materials, including engineered wood waste, plastics and metal, were observed in the wood waste stockpile
during this inspection. See Additional Comments section below for more information.
SUMMARY OF CORRECTIVE ACTIONS REOUIRED:
1. As discussed on site, please submit by March 15'h, a summary of any improvements to the facility
(completed, in progress and planned), a list of capital improvements, and a completion schedule for these
improvements. This will serve to show current status of measures taken and cover the plan of action noted in
the last correspondence from the facility's legal counsel in December 2018. This summary should include a
revised site plan, showing the flow of surface water and leachate, the leachate collection system, the placement
of new equipment/operations, all operations areas (inert debris processing, mixed waste processing, wood waste
processing, etc.) and all waste/product storage areas.
2. An updated Operations Manual, reflecting the revised operational procedures and protocols may be required to
ensure the written narrative matches what is physically occurring on site. Section staff will continue to review
and communicate with facility management if areas of particular concern are noted.
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FACILITY COMPLIANCE INSPECTION REPORT
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Nor Solid Waste Section
OBSERVED VIOLATIONS:
No new violations were observed during this inspection. See comments above and below regarding ongoing activities
to resolve past observed violation.
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.
ADDITIONAL COMMENTS
1. This facility is permitted to receive municipal solid waste (MSW) generated within Alexander, Alamance,
Cabarrus, Catawba, Davidson, David, Forsyth, Guilford, Iredell, Mecklenburg, Randolph, Rockingham, Rowan,
Stokes, Surry, Union, Wilkes and Yadkin Counties. Currently, C&D waste is transported to A-1 Sandrock C&D
Landfill (Permit # 41-17) in Guilford County, and MSW waste is transported to Hanes Mill Road Landfill
(Permit # 34-02) in Forsyth County.
2. This inspection took place on a Thursday afternoon with clear weather and minimal wind. The picking line was
not in operation. Facility staff stated that operations had been halted due to high winds experienced earlier in the
day.
Records Review:
3. The Permit to Operate and approved Operations Manual were available at the facility office for review.
4. Mr. Cosgriff presented a Daily Operations Report that captures the type and tonnage of material received; the
tonnage of waste and the number of transfer trailers that remove it from the facility; outages, equipment issues
and repairs; tonnage of material processed on the picking line and material quality; and, compliance duties and
inspection of the facility. It is noted that the report covers many of the compliance issues raised during previous
inspections related to daily maintenance of the facility. Mr. Cosgriff stated that the new reporting system
provides him with the information needed to evaluate facility operations and staff performance. Daily
Operations Reports from January 2 -30, 2019 were reviewed and verified.
5. Waste screening records for the period December 20, 2018 through January 30, 2019 were available in the
office and reviewed. Waste screening records for the period January 1 through December 19, 201 were
available in the scale house and reviewed as well. All waste screening records were found to be complete,
reflecting the disposition of any unacceptable waste received. Mr. Cosgriff stated that between 2 and 5 random
load inspections are performed during each operating day, adding that he estimated incoming loads to be 20 to
50. These figures indicate that the random load inspection rate exceeds the minimum requirement.
6. Tonnage reports for the current fiscal year were made available for review at the office and yielded the
following monthly figures for waste received during the current fiscal year: July 2018 — 3269.10 tons; August
2018 — 3252.65 tons; September 2018 — 2866.79 tons; October 2018 — 3609.98 tons; November 2018 — 3256.26
tons; and, December 2018 — 2285.95 tons, totaling 18,540.73 tons and averaging 3,090.12 tons per month.
7. Mr. Cosgriff provided a record of the latest stormwater inspection that indicated City of Winston-Salem staff
had visited the site on January 2, 2019.
8. Training records indicated that two facility staff maintain the certification required to operate the facility:
• Joseph Cosgriff — NCSWANA Transfer Station Operations Specialist — expires 9/7/2020;
• Heather Varner — NCSWANA Transfer Station Operations Specialist — expires 3/23/2020.
Mr. Nielsen indicated that he intends to have at least three more staff members train for certification at the next
available class. Please note that a certified operator must be on duty at the facility during all operating
hours.
9. Mr. Cosgriff stated that he typically schedules a safety meeting for all staff members on the last Friday of every
month. He explained that the facility closes to the public on Friday afternoons, and the meetings are scheduled
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to take place after weekly clean-up operations are completed. Records of the facility safety meetings were
reviewed and indicated that the last safety meeting took place on Friday, December 28, 2018.
10. No records of asbestos disposal were available, and Mr. Nielsen stated that asbestos is no longer accepted at the
facility. When asked if a facility staff member was certified to identify and handle asbestos waste that might be
mixed in C&D debris, Mr. Cosgriff stated that Mr. Baker had been certified, but that no one currently on staff
had earned that certification. Mr. Watkins stated that, because the facility deals in demolition waste, at least one
staff member must be certified to identify and handle asbestos should it enter the facility. Mr. Nielsen stated that
he would look into the matter.
Facility Inspection:
11. In general, the facility appeared to be clean and well -maintained at the time of this inspection. Windblown litter
was minimal and well -managed.
12. The facility is secured by chain link fencing with locking gates in areas that are accessible. Unauthorized access
is also prevented by natural topography and dense vegetation in interior areas of the site.
13. Proper signage was observed at the entry to the scale house.
14. Facility access roads are of all-weather construction and were found to be in good condition.
15. A 25' wind screen had been erected around the operations area to capture windblown litter before it leaves the
facility. Mr. Cosgriff stated that this addition has proven to be very effective.
16. The facility was not operating at the time of this inspection, and staff were observed to be conducting cleaning
and maintenance tasks.
Wood Waste Operations:
17. A waste transport trailer was stored on the access road leading to the wood waste operations areas. The trailer
appeared to be in good condition.
18. The south slope of the beneficial fill area that makes up part of the North Site appeared to have been cleared of
unacceptable material. However, the erosion control measures located between the toe of the beneficial fill
slope and the creek, observed from the top of the slope, appeared to be in need of maintenance.
19. The North Site had been cleared of most of the engineered wood waste stockpile. Mr. Cosgriff stated that all of
the engineered wood had been ground and most of it removed for boiler operations that could accept the resins
and glues that are a part of the material. One pile was observed to be all that remained, and Mr. Cosgriff stated
that he anticipated it would be gone within the next week. He explained that the facility will no longer recover
and recycle engineered wood waste; instead, it will be transported to A-1 Sandrock C&D Landfill for proper
disposal.
20. Mr. Cosgriff stated that once the area was cleaned up and restored, the North Site would be used primarily for
product storage.
21. Some areas of frozen ponded water were observed on the North Site, and Mr. Cosgriff stated that maintaining
the site had been difficult with all of the heavy storms experienced over the last six months. He pointed out the
loaded that was mired in mud in the middle of the North Site and stated that he resumes grading and
maintenance of the site when conditions permit.
22. Mr. Watkins stated that the debris visible around the entrance to the North Site raised concerns that some of the
material might not be inert and could include glues and coatings that render it unacceptable for use as beneficial
fill. Mr. Cosgriff voiced his understanding of Mr. Watkins' concerns, stating that staff would be removing
anything from the North Site that appeared to contain contaminants, including the remnants of the engineered
wood waste that had been stored and processed there.
23. The access roadway between the North Site and the Leased Site was found to be in good condition. A number
of empty roll -off containers were stored in this area. When asked about scrap tires that had previously been
stored in one of the containers, Mr. Cosgriff stated that tires are no longer accumulated at the facility, and
instead are sent away in the same truck that brings them or taken to the Hanes Mill Road Landfill for proper
disposal.
24. The Leased Site was occupied almost entirely by a large stockpile of unprocessed wood waste, piles of
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Solid Waste Section
"scalpings" generated by Ingredion, large piles of processed wood waste, and a processing area located in the
center of the site.
25. Access roadways on the leased site were in need of maintenance to repair some areas where equipment ruts had
allowed surface water to pond. Please ensure that water is not permitted to pond in or around wood waste
piles.
26. The wood waste stockpile is generated solely from the picking line. Unacceptable waste was evident throughout
the extensive stockpile area and included plastic buckets, plywood, strapping, plastic film and metal pieces. Mr.
Cosgriff stated that as additional sorting operations are implemented, the amount of unacceptable materials
would be reduced substantially. He added that unacceptable materials are removed from the wood waste as
processing takes place, stating that it would not be safe for staff to try to reach them in the stockpile. Mr.
Watkins stated that these additional sorting operations likely need to be fleshed out and incorporated into the
facility's Operations Manual.
27. A portion of the Leased Site, south of the processing area, has been previously been raised to its current grade
using beneficial fill. During previous inspections, concerns had been expressed by Section staff about
unacceptable material in this beneficial fill area, and about the disposal of mulch/processed wood waste on top
of it. Mr. Cosgriff stated that he had been aware of the concerns relating to this beneficial fill area, but had not
had an opportunity to investigate as yet. As discussed onsite, it is fine to use processed wood chip as temporary
groundcover of no more than 2-3 inches of depth on the side slopes until permanent seeding occurs, however
anything beyond that could be seen as disposal.
Sediment Pond and Surrounding Area:
28. The entrance to the sediment pond area is secured with a locking gate.
29. The slope leading to the forebay and pond were free from windblown litter, and the access road appeared to be
in good condition.
30. No trash was observed in the forebay or in the pond. Mr. Cosgriff stated that trash is removed on a daily basis as
a part of the clean-up operations instituted prior to closing the facility.
31. Mr. Cosgriff stated that two outfalls from the pond are located down the slope on the north side; however, the
outfalls were not visible through the vegetation.
Main Operations Area, Tipping Floor, Picking Line:
32. The gravel and concrete paved areas around the scale house, loading bay and covered tipping floor appeared to
be well -maintained and were free of waste and windblown litter.
33. The area where the loading ramp for the picking line had previously stood was open and clean.
34. All stockpiled waste was observed to be contained under the drip edge of the covered tipping floor.
35. The steel supports of the picking line conveyor were found to have accumulated waste and fines from the
processing line. Mr. Cosgriff stated that these areas are cleaned thoroughly during the half -day facility
maintenance that takes place every Friday afternoon.
36. A small pile of waste was observed on the east side of the picking line, and Mr. Cosgriff stated that staff had
piled the collected waste and debris there for the equipment operator to collect and load into the trailer before
the end of the day.
37. The roll -off containers that collect separated materials from the picking line above appeared to be in relatively
good condition. Mr. Cosgriff stated that containers are being repaired or replaced as quickly as possible. He
added that the stalls in which the containers are staged are cleaned out when containers are replaced throughout
the operating day and also at the end of every operating day.
38. Please ensure that all waste is collected and stored in leak -resistant containers with watertight covers at
the end of every operating day.
39. The bank that runs between the employee parking area and the eastern edge of the main operations area was
observed to be free from windblown litter, as was the fence line that surrounds it. Mr. Cosgriff pointed out the
toe of the bank where he had been working to re-establish the drainageway that is meant to direct surface water
away from the operations area. Additional details relating to proposed changes in the drainage around the
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Solid Waste Section
concrete operations area were shown on a drawing by Beeson & Carter, PA, dated 10/15/2018 and labeled
Sheet No. C-1. Please ensure that these proposed changes in stormwater management are consistent with
the facility's NPDES permit and meet the requirements thereof.
40. The operations area located north of the covered tipping floor had been swept clean and was free of waste and
debris. A loader was parked on the concrete pad, and Mr. Watkins observed that it was leaking oil, as evidenced
by the drops that could be seen coming from the loader and hitting the pavement. He added that equipment
storage and maintenance must take place in an area where stormwater does not flow. Please ensure that this
portion of the operations area is maintained in a clean and sanitary condition so that it accommodates the
sheet flow of clean stormwater.
41. Some waste was observed in the area around the transport trailer parked at the loading ramp. Mr. Cosgriff stated
that this area is policed at the end of every operating day and all waste is collected and placed in the trailer
before it is tarped.
42. During this inspection, facility staff were observed pre-sorting waste on the covered tipping floor manually.
43. Facility staff pulled away the cover on a 20' section of the trench drain, located on the western edge of the
tipping floor. Mr. Cosgriff explained that this section of the drain had been opened to allow leachate to flow to
the sanitary sewer. The remainder of the drain remained filled with crusher run. Liquid was observed to be
flowing freely through this section, having flowed through from the filled end of the trench drain.
Inert Debris Collection & Processing Area and LCID Landfill:
44. The inert debris collection area had been cleaned and reorganized to provide a clear area for trucks to unload
and for facility staff to spread out the waste and remove any unacceptable materials. Loads are inspected prior
to being tipped into the stockpile to await crushing. The tipping area appeared to be adequately sized to allow
the safe maneuvering of trucks and equipment. No unacceptable waste was observed in this area. Mr. Cosgriff
stated that these new inspection procedures would eliminate unacceptable materials in the stockpile.
45. Inert debris is stockpiled on the slope at the south end of the collection area. Mr. Cosgriff stated that crushing
operations take place annually but may be scheduled with more frequency if needed. Unacceptable materials,
including plastic buckets, metal pipe and fencing, wood waste and painted concrete were observed in the
stockpile. Mr. Cosgriff stated that it is unsafe to retrieve the unacceptable materials from the stockpile, and that
they would be separated for proper disposal at the time crushing takes place. He reiterated that the new
procedures would eliminate this problem in the future.
46. The LCID landfill is located on the northwest side of the inert debris storage and processing area. Mr. Cosgriff
stated that no landfilling is taking place at the facility. Please install permanent edge -of -waste markers that
accurately identify the waste boundary of the landfill to protect the landfill cap from the encroachment of
facility equipment and operations.
47. A trailer is located on the south side of the inert debris processing area. The trailer and surrounding area had
previously been used for equipment and vehicle maintenance and for the storage of spare parts. Mr. Cosgriff
stated that all maintenance now occurs in the maintenance building, situated southwest of the scale house. He
added that some of the clean metal spare parts remain in and under the trailer and are pulled as needed. The
trailer area was observed to be clear of waste and windblown debris.
48. A stockpile of gypsum is staged west of the trailer and is covered completely by a tarp. Piles of crushed inerts
were also stored in this area and appeared to be well -maintained.
49. Mr. Watkins observed that stormwater entering this area from the re-established drainageway in the operations
area might need to be redirected to avoid contact with the waste, or that the storage piles of inerts be kept away
from the ditch itself. He also pointed out that surface water flow in the ditch lines along Overdale Rd and into
the roadway leading to the inerts area from the adjoining South Site should be addressed. Some excavation
work had been observed, done to clear debris from a section of the drainage way below the entrance culvert,
that could be interpreted as a new discharge location. It is recommended that any drainage improvements
and modifications be reviewed with the City of Winston-Salem inspector to determine whether
modifications to the existing approved plan are required.
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Solid Waste Section
South Site:
50. The South Site has been used for the storage of processed residuals from the picking line. Discussion continues
between facility staff and the Solid Waste Section to determine appropriate procedures that will be required for
the future storage and processing this material.
51. Currently, the South Site still contains approximately 75% of the processed residual stockpile that had been
identified in the original Notice of Violation, dated March 21, 2017. Interim procedures that had been agree to
by facility staff and the Solid Waste Section in the fall of 2017 require that the material be re -processed and
removed from the site. Mr. Cosgriff stated that overwhelming weather problems and equipment issues as well
as the significant underestimation of the size of the stockpile had resulted in this small amount of progress. He
explained that the new screening procedures were producing a much finer material that appeared to be
composed mainly of the wood, cellulose material and inerts, as originally intended.
52. The stockpile of processed residuals, in an area extending from the entrance to a point approximately 120' into
the site, had been reprocessed and moved so that the land had been restored to its original contours.
53. Piles of the reprocessed material had been moved to the southern half of the South Site, outside of the stockpile
area, for storage until a determination about the use of the material can be made. Mr. Cosgriff stated that the
intention is to blend the reprocessed material from the South Site with processed wood waste or scalpings to
produce a soil amendment.
54. A large horizontal screener was also staged on the southern side of the South Site where it is used to reprocess
the "legacy" stockpile as weather permits. As a reminder, the previously approved sampling plan to be used for
the "legacy" stockpile material after it is rescreened remains in effect prior to distribution/sale of this material.
55. The South Site had been cleaned up since the previous inspection on April 24, 2017, and minimal windblown
litter and unacceptable waste was visible from the entrance to the site. Remaining stockpiles of the processed
residual were high enough to block the view of the surrounding wood line, so it was not possible to evaluate the
extent of windblown trash on the South Site as a whole.
56. Please note that any changes to the original erosion and sedimentation control plan may necessitate a
plan modification. Please provide evidence of a review of the erosion and sedimentation control measures
for the facility by City of Winston-Salem Erosion Control staff.
A view of the inert debris tipping area, now reorganized to provide adequate space for vehicles and equipment to
maneuver safely. (Photo taken by J. Watkins 1131119.)
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-.,,D-EQ
NIF
A view of the North Site with
the unprocessed engineered
wood waste stockpile removed.
Maintenance is being
performed to regrade the site
and remove the residue of any
unacceptable material. (Photo
taken by S. Heim 1131119.)
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
M
A view of the roadway leading from the
locking gate on Overdale Road to the South
Site. All of the windblown litter that had
been observed in this area during the
previous inspection had been cleaned up,
and the roadside was free from waste and
debris. (Photo taken by J. Watkins 1131119.)
V
Page 12 of 13

FACILITY COMPLIANCE INSPECTION REPORT
DE Q Division of Waste Management
NIF Solid Waste Section
Right: The container storage area,
located between the North and Leased
Sites, has been cleaned and regraded.
(Photo taken by S. Heim 1131119.) U.
Below: A large tub grinder can be
seen near the center of the Leased Site
surrounded by processed and
unprocessed wood waste.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan Heim
S Susan Heim, o=Solid
Waste
Section, ou,
email=[e-mail]
v, c=US
Date: 2019.02.11 10:53:16
05'00'
Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: February11, 2019 to
X
Email
Hand delivery
US Mail
Certified No. [ ]
Roger Nielsen
Copies: Jason Watkins, Field Operations Branch Head — Solid Waste Section
Deb Aja, Western District Supervisor — Solid Waste Section
Ming-Tai Chao, Permitting Engineer — Solid Waste Section
Joseph Cosgriff, Operations Manager — Abbey Green, Inc.
Page 13 of 13