1905_INSP_20191210

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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1UNIT TYPE:
Lined MSWLF LCID YW Transfer Compost X SLAS COUNTY: Chatham
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 19-05
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: December 10, 2019 Date of Last Inspection: January 11, 2018
FACILITY NAME AND ADDRESS: Brooks Compost Facility – Large Type 3 Solid Waste Compost Facility 1195 Beal Road Goldston, NC 27252 GPS COORDINATES: Lat.: 35.54431 Long.: -79.36780 FACILITY CONTACT NAME AND PHONE NUMBER: Amy Fulford, Assistant Facility Manager – Brooks Contractor
w. 919-837-5914 f. 919-837-5097 c. 919-842-6063
[e-mail] www.brookscontractor.com FACILITY CONTACT ADDRESS:
Brooks Contractor Amy Fulford, Assistant Facility Manager
1195 Beal Road
Goldston, NC 27252
PARTICIPANTS: Chuck Kirchner, Environmental Senior Specialist – Solid Waste Section (SWS)
Deb Aja, Western District Supervisor – Solid Waste Section (SWS) Amy Fulford, Assistant Facility Manager – Brooks Contractor Alan Brooks, Site Manager – Brooks Contractor
STATUS OF PERMIT:
Permit to Operate (PTO) issued August 20, 2015 PTO expiration date January 22, 2020 Application for Permit Renewal Received by Solid Waste Section on September 27, 2019 PURPOSE OF SITE VISIT:
Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS:
None OBSERVED VIOLATIONS: None
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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ADDITIONAL COMMENTS
On January 11, 2018, Chuck Kirchner met with Amy Fulford and Alan Brooks to conduct a comprehensive inspection of the Brooks Compost Facility – Large Type 3 Solid Waste Compost Facility on Beal Road in Goldston, Chatham
County.
1. The facility is a Large Type 3 Solid Waste Compost (SWC) Facility. It produces compost from eggshell/hatchery waste, food waste (pre-consumer and post-consumer), yard waste (primarily leaves), wood mulch, animal bedding, grease trap waste, etc. (see facility operations & maintenance manual pages 6 and 7) and additional materials as approved by the Solid Waste Section (SWS).
2. Changes requested in the permit renewal include an area set up for an aerated static pile, an increase in tonnage from 75,000 tons to 100,000 tons max capacity annually and the inclusion of OFFAL poultry material.
3. The facility is in operation Monday through Friday 7:00 am to 5:00 pm and Saturday 8:00 am to 12:00 pm. 4. The facility permit, site plan, and operations plan were discussed. 5. Compost produced is primarily sold to construction and landscape contractors, farmers, and landscape
supply businesses. 6. Compost produced may be mixed with sand, pine bark fines, PermaTill, or per individual custom blend formula. 7. Upon receipt, liquid material is dumped into a mixing and bulking pit. Bulking agents are added to the liquid material and the material is mixed. 8. The mixture is then placed on an adjacent concrete pad to drain.
9. The two 3,500-gallon concrete storage tanks are no longer used. Leachate from the concrete pit and/or pad is re-mixed with additional bulking agents and added to the active windrows. 10. Food waste is placed on the concrete pad, mixed with bulking material, and placed in windrows.
11. Eggshell/hatchery waste is placed in windrows upon receipt. It is mixed with bulking materials as the windrow is constructed. A layer of uncured compost is placed atop the windrow during its construction. 12. The facility commonly uses leaves, cardboard, mulch, animal bedding, and yard waste as bulking material.
13. The facility receives leaves during the leaf collection season from the Town of Cary and the Town of Siler City. 14. Active windrows are organized into two separate operational areas: eggshell/hatchery waste and food waste. 15. Runoff from the windrow areas goes into a leachate pond located at the southeast corner of the windrows.
The leachate is pumped-out and used to irrigate active windrows in the first 30-50 days of the windrow. 16. Active windrows appeared to be within required dimensions and had the required spacing between windrows. 17. During the inspection, the facility had 43 active windrows. 18. The facility uses a windrow-turning machine to turn the active windrows. Windrows are constructed with a front-end loader. 19. The front-end loaders use separate quick attach buckets on the different windrow areas to prevent cross contamination. 20. Active windrows are commonly maintained for 2 to 6 months during which time the process to further reduce pathogens (PFRP) is met. Windrows that have met PFRP are combined into a curing pile. Material is generally cured for an additional 4 to 12 months. 21. The facility maintains three curing piles. Material to be cured is placed at one end and cured material/compost is removed from the other. 22. Stockpiled curing material/compost is limited to a height of 60 feet. Curing stockpiles appeared to be approximately 30 feet in height during this inspection.
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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23. Compost is screened prior to sale. Screening rejects are recycled into the active windrows.
24. The facility annual report (FAR) dated July 30, 2019 was received by the SWS. Material received for July 2018 through June 2019 is 56,370.15 tons. The amount of compost created is 32,632.38 tons, the amount sold/given- away is 23,632.38 tons, and the amount stockpiled on site is 8,937.31 tons. 25. The facility maintains records of the quantity, type, and source of material received for processing. The amount of material received from July 1, 2019 through December 10, 2019 is 25,368.66 tons. 26. The facility produces Grade A compost and offers an information pamphlet for customers and maintains a website containing user information.
27. The facility has three temperature probes. The temperature probes are calibrated monthly. Temperature probe calibration records for January 15, 2018 to November 15, 2019 were observed. 28. The facility no longer uses Green Mountain Technologies, Inc. windrow manager software to electronically maintain active windrow data. Brooks Contractors have developed an excel spreadsheet to capture the relevant information. The excel spreadsheet appeared to capture all required information. 29. Windrow records were observed for 2018 and 2019. Records for temperature, turning intervals, moisture
level, bulk density, and C:N calculation are maintained. PFRP was met on all windrows except one test windrow that did not pass and was recycled into another active windrow which later passed PFRP. 30. Compost analysis records were observed for nutrients, concentration of metals, manmade inerts, fecal coliform, and salmonella for samples observed for April 25, 2018, December 20, 2018, April 25, 2019 and May 10, 2019. The compost samples were analyzed by Soil Control Lab, Watsonville, CA. Mrs. Fulford stated that a new lab might be used to conduct the sampling soon. Compost sample analysis appeared
compliant with Solid Waste Section rules. Ms. Fulford stated that compost analysis will be conducted ~ every four months. 31. The facility has one water truck for dust control and one for windrow irrigation. 32. There was no odor detected at the facility boundary. 33. Mr. Brooks stated that the facility has not received an odor complaint. Eggshell/hatchery waste is incorporated into windrows upon receipt, covered with a layer of compost, and commonly turned when winds are favorable. 34. The facility has a clay-lined stormwater pond. Stormwater can be pumped-out for use on windrows/in the active compost process. 35. The stormwater pond freeboard appeared to be at ~ 2 feet during this inspection. 36. Continue to repair and maintain the three stormwater pond sediment basins and stormwater pond as necessary.
37. The facility had been issued a Division of Water Resources Land Application (Irrigation) of Industrial By Product Compost Leachate and Stormwater Runoff permit, No. WQ0036333, issued: 11/17/14 - expiration: 09/30/18. A letter was issued by the Division of Water Resources on June 14, 2019 stating that the subject
permit is no longer required. 38. The Goldston Fire Department can be contacted to address and emergency at the facility. 39. The facility is secured by a metal gate with lock (the Brooks’ residence is located at the entrance drive to the facility). Facility personnel are on site during operating hours. 40. Access roads are of all-weather construction. 41. The facility has proper signage.
42. Effective November 1, 2019 15A NCAC 13B .1406 (19) (a) states in part that this facility “shall have an operator, supervisor or manager trained in accordance with the requirements in G.S. 130A-309.25.” Training requirements must be achieved and maintained by the US Composting Council Certification Commission or equivalent and this training shall be required every five years. 43. Per 15A NCAC 13B .1406 (19) (d) The above requirement shall be met by this facility within three years of the readopted rule date of November 1, 2019.
44. 15A NCAC 13B .1406 (19) (b) & (c) states “Owners or operators shall provide annual training for facility staff, including a review of the operations plan and permit documents. Documentation of training required in Sub-items (a) and (b) of this Item shall be maintained at the facility and made available to the Division upon request.”
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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45. The PTO expiration date is January 22, 2020. 46. The PTO renewal application was received by the SWS on September 27, 2019 and is currently under review.

Please contact me if you have any questions or concerns regarding this inspection report. Phone: [phone] Chuck Kirchner Environmental Senior Specialist Regional Representative

Sent on: December 17, 2019 X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor - Solid Waste Section