34_N0667_INSP_20190614

oepamnem a� enmmnmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
X
YW
X
Transfer
Compost
SLAS
COUNTY: Forsyth
MSWLF
PERMIT NOS.: N0667 and YWN-34-014
Closed
HHW
White
Incin
T&P
FMM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
Tire T&P /
Tire
industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: June 14, 2019 Date of Last Inspection: October 25 and November 2, 2018
FACILITY NAMES AND ADDRESS:
Westmoreland, Inc. LCID Landfill
Westmoreland, Inc. Type 1 Compost Facility
6250 Walnut Cove Road
Walkertown, NC 27051
GPS COORDINATES: N: 36.196416' W:-80.164851'
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Tom Westmoreland, President, J. Westmoreland, Inc.
Telephone: [phone] (office); 336-345-3586 (mobile).
Email address: [e-mail]
FACILITY CONTACT ADDRESS:
J. Westmoreland, Inc.
6851 Old Still Trail
Kernersville, NC 27284
PARTICIPANTS:
Tom Westmoreland, President — J. Westmoreland, Inc.
Dustin Mabe, Facility Operator — Westmoreland LCID Landfill
Elizabeth Walter, Administrative Staff — Westmoreland LCID Landfill
Jim Bryan, Consultant — Westmoreland LCID Landfill
David Evans, Erosion Control Inspector — City of Winston-Salem
Danielle Felske, Zoning Inspector — City of Winston-Salem
Ming-Tai Chao, Permitting Engineer — Solid Waste Section
Susan Heim, Environmental Senior Specialist — Solid Waste Section
STATUS OF PERMIT:
LCID Landfill Notification submitted and recorded in Forsyth County on March 17, 2005;
Yard Waste Notification 34-017 was approved September 18, 2017 and expired May 31, 2019.
PURPOSE OF SITE VISIT:
Partial Inspection
STATUS OF PAST NOTED VIOLATIONS:
See items A and B below in the N0667 portion of the Observed Violations section of this report for information about
status of past noted violations.
OBSERVED VIOLATIONS:
Violations Relating to Notified LCID Landfill N0667:
Page 1 of 9

D_E FACILITY COMPLIANCE INSPECTION REPORT
DO Ctd—iA Q�� Division of Waste Management
OepaNnen� e� Envimnmenlal pualiry
Solid Waste Section
A. 15A NCAC 13B .0566(4) states: "Adequate soil cover shall be applied monthly, or when the active area reaches
one acre in size, whichever occurs first."
J. Westmoreland, Inc. is in violation of 15A NCAC 13B .0566(4) for failing to cover waste monthly with
adequate soil cover.
In the facility inspection report, dated October 25, 2018, a compliance deadline of December 31, 2018 was set for
covering all waste with a minimum of one foot of clean soil. The exposed waste observed on the northern and
eastern slopes of the landfill during the previous inspection on October 25, 2018 was again observed during this
inspection. In addition to the uncovered land clearing and inert debris that was observed to be stored on top of the
landfill during the previous inspection on October 25, 2018, more land clearing debris had been added to the
stockpile.
B. 15A NCAC 13B .0566(3) states: "Solid waste shall be restricted to the smallest area feasible and compacted as
densely as practical into cells."
J. Westmoreland, Inc. is in violation of 15A NCAC 13B .0566(3) for failing to restrict solid waste to the
smallest area feasible.
In the facility inspection report, dated October 25, 2018, a compliance deadline of December 31, 2018 was set for
compacting all waste into as small an area as feasible. During this inspection, slope grades were observed to be
almost vertical. Waste on the exposed slopes of the landfill appeared to be loosely piled, indicating that waste had
been pushed off the top of the working face instead of being placed in the landfill in lifts and compacted as it was
placed. Mr. Mabe stated that the grades are too steep to maneuver the heavy equipment needed to achieve
compaction of the waste and confirmed that waste had not been compacted.
C. 15A NCAC 13B .0566(2) states, "The facility shall accept only those wastes which it is permitted to receive."
J. Westmoreland, Inc. is in violation of 15A NCAC 13B .0563(1)(a) for accepting waste that it is not
permitted to receive.
During this inspection, painted wood, plywood, plastics and scrap metal were observed at the northeastern edge of
the top of the landfill; and, painted concrete, concrete containing metal pipe, scrap tires and tire pieces, scrap
metal and plastics were observed near the power lines, in an area where old equipment and parts are stored.
Unacceptable wastes piled near the
inert debris/ground wood waste
stockpile, southwest of the LCID
landfill area — scrap tires and tire
pieces, scrap metal, plastics.
Page 2 of 9

oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Plywood, painted wood and scrap metal
are mixed with ground wood waste at the
top of the western edge of the LCID
landfill.
D. 15A NCAC 13B .0563(1)(b) states, in part, that an individual permit from the Division of Solid Waste is not
required for Land Clearing and Inert Debris (LCID) landfills where the total disposal area is under two acres in
size.
J. Westmoreland, Inc. is in violation of 15A NCAC 13B .0563(1)(a) for expanding the disposal area beyond
the two -acre size limit without having a permit to do so.
Based on the review and comparison of aerial photographs, it is estimated that the current disposal area of the
LCID landfill is at least 2.5 acres in size. (See aerial site map below.)
Violations Relating to Notified Yard Waste Facility YWN-34-014:
A. 15A NCAC 13B .1402(g)(3) states, in part, that a permit is not required for small Type 1 facilities that occupy
less than two acres of land and process or store less than 6,000 cubic yards of material per quarter.
J. Westmoreland, Inc. is in violation of 15A NCAC 13B .1402(g)(3) for processing or storing more than
6,000 cubic yards of material per quarter.
The current stockpile of windrowed material exceeds the 6,000 cubic yard limit. Through observations made
during this and previous inspections, and by measuring the size of the windrows seen in aerial photographs taken
in February 2019, it is estimated that the processed wood waste in the four distinct windrows in the compost area
alone is at least 8,000 cubic yards. In addition, piles of processed wood waste (mulch) and wood grinding
operations were observed to be staged in other areas of the site.
B. 15A NCAC 13B .1402(g)(3) states, in part, that a permit is not required for small Type 1 facilities that occupy
less than two acres of land and process or store less than 6,000 cubic yards of material per quarter.
J. Westmoreland, Inc. is in violation of 15A NCAC 13B .1402(g)(3) for operating a small Type 1 facility
that occupies more than two acres of land without a permit.
Page 3 of 9

D_E FACILITY COMPLIANCE INSPECTION REPORT
NOFTH CAaOLiNA Division of Waste Management
OepaNnent d Envimmemal Oualiry
Solid Waste Section
Based on the review of aerial photographs, the compost area, located to the southwest of the asphalt/marble
stockpile area, occupies approximately two acres of land. The total acreage is increased by additional wood waste
stockpiles and operations located in various areas throughout the site.
COMPLIANCE DEADLINE AND CORRECTIVE ACTIONS REQUIRED:
To achieve compliance, J. Westmoreland, Inc., shall complete the following corrective actions by August 31, 2019
or as otherwise noted below:
• Immediately cease accepting waste at the LCID landfill.
• Immediately cease accepting waste at the yard waste/compost facility.
• Immediately collect and properly dispose of all unacceptable materials from the landfill area and throughout
the site. Copies of disposal receipts for unacceptable materials shall be provided to Susan Heim.
• For the notified LCID landfill facility N0667:
o Reduce the size of the existing disposal area of the LCID landfill to less than 2 acres.
o Remove all waste outside the disposal area and properly dispose of it at a facility that is permitted to
accept it.
o Ensure that the landfill is constructed in lifts, with proper slopes and compaction.
o Install permanent edge of waste markers that are visible by line of sight around the entire perimeter of the
waste disposal boundary.
o Apply a minimum of 12" of clean soil cover to the landfill disposal area, sloped to allow surface water
runoff in a controlled manner.
o Seed the waste disposal area and establish a vegetative cover sufficient to restrain erosion.
o Submit a survey that clearly and accurately delineates a waste disposal area of less than 2 acres for the
LCID landfill.
o Submit a report from a registered engineer or PG, certifying the required 12" of clean soil cover using at
least four borings per acre.
o Provide copies of disposal receipts for all waste removed from the landfill for proper disposal to Susan
Heim.
For the notified yard waste/compost facility YWN-34-014:
o Submit a site plan that clearly delineates the boundary and size of the compost area where all windrows
are staged and all wood waste stockpile and grinding operations take place;
o Remove all wood waste (including processed and unprocessed materials) that exceeds 6,000 cubic yards
and properly dispose of it at a facility that is permitted to accept it;
o Provide copies of disposal receipts for all waste removed from the yard waste/compost facility for proper
disposal to Susan Heim.
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.
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D_E FACILITY COMPLIANCE INSPECTION REPORT
NOFTH CAaOLiNA Division of Waste Management
OepaNnent d Envimmenlal Oualiry
Solid Waste Section
ADDITIONAL COMMENTS:
1. The facility includes a notified LCID landfill and notified yard waste facility.
2. Edge -of -waste markers for the LCID disposal area were not visible at the site.
3. A meeting took place prior to the inspection at the facility office during which facility operations and
compliance issues were discussed.
4. Ms. Felske expressed concern that the 100' buffers required as a part of the facility's special use permit were
not being met. She stated that she would confer with her supervisor and keep all parties apprised of any action
taken by the city's zoning enforcement and any corrective action to be required as a result.
5. The inert debris stockpile, located to the east of the landfill access roadway, had been covered with a stockpile
of processed wood waste. Mr. Westmoreland stated that they had run out of storage room elsewhere.
6. A stockpile of large timbers that resembled railroad ties was staged just south of the inert debris/processed
wood waste stockpile. Mr. Westmoreland stated that these timbers were clean wood and not coated or treated
with creosote.
7. Stockpiles of processed and unprocessed wood waste were occupying the top the LCID landfill disposal area.
8. Unacceptable materials, including painted wood, plywood, scrap metal, and plastics, were observed to be mixed
in with processed wood waste along top of the northeastern slope of the landfill. (See Observed Violations
section of this report for additional information.)
9. A pile of unacceptable materials was observed near the power lines in the vicinity of an old equipment and parts
storage area. The pile included scrap tires and tire pieces, scrap metal, concrete embedded with metal pipe, and
plastics. (See Observed Violations section of this report for additional information.)
10. Exposed waste was visible on the side slopes of the LCID landfill unit.
11. The yard waste notification renewal, obtained on June 18, 2019 for YWN-34-014, does not authorize J.
Westmoreland, Inc. to receive waste at this site until J. Westmoreland, Inc. comes into compliance with
15A NCAC 13B.
12. An area south of the LCID landfill was observed to contain inert debris. Mr. Westmoreland stated that this area
is a "beneficial fill area." All inert debris accepted at the landfill for disposal is included in the landfill
footprint. The area referred to as a "beneficial rill area" is not a Beneficial Fill in accordance 15A NCAC
13B .0562. Ensure that all inert debris disposed of at the facility is included within the boundary of the 2-
acre LCID landfill on the site plan submittal.
13. Yard waste operations, including unprocessed wood waste stockpiles, mulch and compost windrows, and
grinding operations, were observed to be taking place in various locations at the site and occupying more than 2
acres of land. (See Observed Violations section of this report for additional information.)
14. A pile of logs and stumps was staged in a long line on the western side of the landfill near the toe of the slope.
Mr. Mabe stated that he had begun to collect the large pieces of wood waste that had rolled off the landfill
slopes toward the creek.
15. Temperature logs for the compost operations were not available for review during the inspection. Ensure that
temperature logs are maintained at the facility and available for review upon request.
16. Following this inspection, a Notice of Violation, dated June 18, 2019, was issued by the City of Winston-Salem
Erosion Control Division citing J. Westmoreland, Inc. for failure to follow an approved erosion control plan,
failure to install and maintain erosion control measures, and failure to keep current self -inspection records. The
notice required submittal of an erosion control plan for the site within 14 days of receipt.
Page 5 of 9

oepamnem a� enmmnmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Aerial photograph from Google Earth dated February 2019 with labels added to identify operational areas and site features.
Forsyth County Tax Map with labels added to identify the 3 J. Westmoreland, Inc. -owned parcels that make up the site.
Page 6 of 9

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Behind the large horizontal grinder, ground wood waste is mounded on top of an inert debris stockpile, southeast
of the LCID landfill.
A view of the south side of the inert debris stockpile with ground wood waste mounded on top. Note the pile of large
timbers resembling railroad ties in the left foreground.
Page 7 of 9

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
NOFTH CAaOLiNA
OepaNnent d Envimmenlal Oualiry
Solid Waste Section
Large logs and stumps are
arranged in a long line near
the toe of the western landfill
slope. Note the sediment that
flowed from the landfill into
the line of wood waste (inset
below).
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S
Page 8 of 9

oepamnem a� enmranmemai a�ai
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
_`j
7" `1 A view from the top of the north side of
the LCID landfill looking down the
266- d uncovered, near -vertical slope.
Please contact me if you have any questions or concerns regarding this inspection report.
Digitally signed by Susan Heim
Susan Heim, l Solid
Waste Section, ou=Field Operations Branch,
email=[e-mail],
c=US
Date: 2019.07.12 09:36:20-04'00'
Phone: [phone]
Susan Heim
Environmental Senior Specialist
Regional Representative
Sent on: July 12, 2019 to Tom
X
Email
Hand delivery
US Mail
Certified No. 1I
Westmoreland, J.
Westmoreland, Inc.
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
David Evans, Erosion Control Inspector — City of Winston-Salem
Danielle Felske, Zoning Inspector — City of Winston-Salem
Jim Bryan, Consultant — Westmoreland LCID Landfill
Page 9 of 9