34_N0667_CORR_20200330

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL SCOTT
Director
Sent via email: [e-mail]
Mr. Tom Westmoreland
J. Westmoreland, Inc.
6851 Old Still Trail
Kernersville, NC 27284
NORTH CAROLINA
Environmental Quality
March 30, 2020
SUBJECT: Compliance Plan Review
J. Westmoreland, Inc.
Permit ID Numbers N0667 and YWN-34-014
Forsyth County
Dear Mr. Westmoreland:
We appreciate your willingness to meet with Field Operations Branch staff on March 18, 2020. Even
though our "meeting" was a conference call, I believe the time that we all invested was helpful in
moving forward with your plans to bring the site back into compliance. This correspondence includes
information relating to outstanding compliance issues at both the LCID landfill and at the 2-acre
approved Yard Waste Notification site.
Based on our discussions, I've provided a list of items for you to address and submit back to us for
review and approval. We apologize in the delay in providing this information but in keeping with the
2-week time frame we'd agreed to on March 18th, I'd appreciate your response by April 10, 2020.
What follows is a list of the additional information needed from you.
Provide Benchmarks and key check -in dates for the following activities, with activities to be
completed no later than June 1.2020:
• Update the site plan maps, dated February 3, 2020, to make terminology more consistent
using the following definitions and guidelines:
o All land clearing waste, brush and stumps that have not been ground for mulch and
are stored in piles throughout the site should be labeled as "Unprocessed Wood
Waste Stockpile."
o All wood waste that has been ground into mulch and has been stored in piles
throughout the site should be labeled as "Processed Wood Waste Stockpile."
o Clean soil that has not been mixed with wood waste or other material and is stored in
piles throughout the site should be labeled as, "Clean Soil Stockpile."
NORTH CAROLJNAD_E Q�
Department of Environmental Duality
North Carolina Department of Environmental Quality I Division of Waste Management
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

Mr. Tom Westmoreland
Compliance Plan Review
Page 2 of 3
March 30, 2020
o Soil that is mixed with waste or other material and is stored in piles throughout the
site should be labeled as, "Mixed Waste Stockpile."
o All used concrete, brick and block that have not been crushed, are not mixed with
other waste, and are stored in piles throughout the site should be labeled as, "Inert
Debris Stockpile." This does not include any inert debris that was separated and
buried on the site.
o Any areas where wood waste, inert debris and soil have been disposed of by burying
should be included in the existing landfill disposal area footprint. The landfill disposal
area should be delineated and labeled as, "Existing LCID Landfill."
o Any areas that have been filled only with inert debris (concrete, block, brick, soil)
should be delineated and labeled as, 'Beneficial Fill."
• Construct erosion control devices to ensure that surface water is controlled on the site.
(Please provide us with a copy of the revised erosion control plans approved by Forsyth
County.)
• Remove all waste that is currently located on the top of the LCID landfill from the site.
• Survey and mark the perimeter of the recorded, approved 1.99-acre LCID landfill parcel.
• Provide a phased grading plan that includes interim benchmarks to track progress.
Provide benchmarks and key check -in dates for the following activities, with the activities to
be completed no later than December 31, 2020:
• Begin removal/processing of waste currently landfilled outside of the 1.99-acre landfill
parcel.
• Process material in the inert debris stockpile and remove it from the site.
• Complete the removal/processing of waste outside of the 1.99-acre landfill parcel.
• Lower the elevation of the 1.99-acre LCID landfill by removing waste in lifts and processing
it.
Remove processed waste from the site.
Ensure the construction of side slopes to a maximum grade of 3:1.
• Apply at least 12" of clean soil to the 1.99-acre LCID landfill as final cover and seed to establish
a vegetative cover sufficient to prevent erosion. Provide documentation to verify the 12"
depth of cover by taking at least 4 borings per acre.
NORTHCAROLINAD_E Q�/�I
Qepar ent of Envlmnmemal Qual\
North Carolina Department of Environmental Quality I Division of Waste Management
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

Mr. Tom Westmoreland
Compliance Plan Review
Page 3 of 3
March 30, 2020
Submit final as -built drawing showing the disposal area, elevation, and documenting the
required 3:1 slope:
• Within 30 days of completing the cover activities for the closure of the LCID landfill, submit
an as -built drawing showing the final 1.99 acre landfill disposal area with contours
documenting 3:1 side slopes and the final elevation, property lines, and other uses such as
the beneficial fill area.
With regard to the Yard Waste Notification site, provide benchmarks and key check -in dates
for the following activities, with the activities to be completed no later than December 31,
2020, except as otherwise indicated below:
• Reduce the stockpile of processed wood waste/mulch to 6,000 cu. yds. or less on the
approved 2-acre yard waste site.
Provide documentation that includes the disposal or end -user location and the volume of
material removed from the site to each location.
• Ensure that the next annual renewal for the Yard Waste Notification site is filed with the Solid
Waste Section no later than June 1. 2020, as required.
I believe I've covered the outstanding issues relating to the compliance of the site. The time frame
included here was constructed based on the comments submitted in your narrative dated January 24,
2020 as well as our discussions on March 18, 2020. However, please don't hesitate to contact me if
you have any questions or concerns.
Thank you,
Digitally signed by Susan Heim
' / DNn=Susan Heim, o=Solid
i, Waste Section, ou=Field
Operations Branch,
e m a i l=s u sa n, [e-mail]
, c=US
Date: 2020.03.30 16:03:10
-04,00,
Susan Heim
Environmental Senior Specialist
Solid Waste Section
Cc: Jason Watkins, Field Operations Branch Head
Deb Aja, Western District Supervisor
Jim Bryan
Alex Carter, Beeson & Carter, P. A.
NORTHCAROLINAD_E Q�/�I
Qepar ent of Envlmnmemal Qual\
North Carolina Department of Environmental Quality I Division of Waste Management
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800