9213_RaleighYW_mitigation_20200326

City of Raleigh Yard Waste Center
Solid Waste Inspection Mitigation Plan
Revision 2
City of Raleigh Solid Waste Services
630 Beacon Lake Drive
Raleigh, North Carolina 27610
919-996-6890
02219101.00 1 March 26, 2020
319 Chapanoke Road, Suite 11 14D
Raleigh, NC 27603
919-662-3015

Table of Contents
Section Page
1 Facility Background Information...................................................................................................1
FacilityDescription.............................................................................................................................1
2 Observed Violations and Additional Comments............................................................................1
3 Facility Modifications and Planned Actions..................................................................................2
Addressing NCDEQ Comments/Plan to Address Stockpiles..................................................3
Exhibits
Exhibit 1. Anticipated Timeline.............................................................................................................5
Exhibit2. Material Volumes..................................................................................................................6
Tables
Table 1. Volume and Weight Calculations.........................................................................................4
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FACILITY BACKGROUND INFORMATION
FACILITY DESCRIPTION
The City of Raleigh Yard Waste Center (YWC) opened in November 1992. The facility is located on the
east side of New Hope Road southeast of the closed Wilders Grove Landfill. The facility is operated
by the City's Solid Waste Services Department. The facility address is:
900 New Hope Road
Raleigh, NC 27602
[phone]
The YWC normally accepts yard waste and brush material including grass clippings, shrubbery
trimmings, leaves, tree limbs, logs, and pine straw. These vegetative waste materials are accepted
for treatment and processing via chipping/grinding or composting. No disposal is conducted at the
YWC. The YWC is permitted as a Large Type 1 Solid Waste Compost Facility on the basis of the
definition contained in Section .1402 (f)(1) and (f)(7) of the NC Solid Waste Regulations.
Portions of the facility are used to process storm debris from hurricanes, ice storms, and other
natural disasters when necessary. Such debris may be processed by City staff or by a U.S. Army
Corps of Engineers contractor. These activities are generally confined to permitted processing areas.
Finished products (compost, mulch, wood chips and leaves) are sold directly to the public after
processing. City departments other than Solid Waste Services use finished products at no charge for
various applications.
2 OBSERVED VIOLATIONS AND ADDITIONAL COMMENTS
On January 13, 2020, a Facility Compliance Inspection was conducted by the NCDEQ, DWM, Solid
Waste Section. In the Facility Compliance Inspection Report (Inspection Report), under "Status of
Past Noted Violations:" and "Observed Violations:," there are no entries.
Under "Additional Comments:" the Report stated:
1. Hardwood logs were being stored on top of the closed LCID landfill for the purpose of
grinding into hardwood mulch (Figure 1). Mr. Gainer thought that area was approved as part
of the operational area, however it is not (view approved operation plans and drawing (G-3)).
Immediately cease using this area for any operational purposes. Within 30 days, remove all
material on top of the LCID landfill and make necessary repairs to the cap.
2. Stockpiled material:
a. Within 30 days, the Solid Waste Inspection Mitigation Plan, submitted to the
Section January 2018, must be updated to include how the City will address
Stockpile 2 and the Leaf Stockpile along with a timeline for compliance.
b. City of Raleigh, Yard Waste and Recycling Facility has stopped adding incoming
material to the stockpile areas. However, the City must come into compliance with
G.S. 130A-309.05.(c)(1) which states Seventy-five percent (75%), by weight or
volume, of the recovered material stored at a facility at the beginning of a calendar
year commencing January 1, shall be removed from the facility through sale, use, or
reuse by December 31 of the same year. Material must be processed and removed
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from the site on a regular basis, so that 75 percent, by weight or volume, of material
is removed within a calendar year of receipt. In other words, yard waste and compost
facilities are not approved for permanent storage or final disposal.
c. Stockpile 2 has been sampled and drilled to find the depth of the pile. The depth
varies up to 31 feet deep. A report of the sample results is to be submitted to the
Section.
d. Stockpile 1 has been removed.
e. The Leaf Stockpile had some of the material removed, but a large majority of it
remains.
3. Leaf stockpiles and some composting windrows had water ponding in and around the waste
(Figure 2). According to 15A NCAC 13B .1406 (3) "Stormwater shall be diverted from
operations area." As soon as these areas are dry enough to work in them, regrade to create
positive drainage.
4. We were unable to view some areas of the facility due to wet conditions making the roads
muddy and impassable. According to 15A NCAC 13B .1406 (5)(c), "The access road to the
site shall be of all-weather construction and maintained." Within 30 days, repair roads so
that they are all-weather.
5. The total capacity of the site is 169,750 tons per year (includes leaf storage and windrow
areas). A permit modification is required for a request to increase capacity. 15A NCAC 13B
.1406 (16) The amount of compost stored at the facility shall not exceed designed storage
capacity. A survey of the waste and windrows to include the leaf storage areas should be
conducted to ensure that the City is not over the approved capacity for this site. This was
also noted in Liz Patterson's August 13, 2018 Inspection Report.
6. The facility's permit expired on October 18, 2017. A permit renewal application has been
submitted to the Solid Waste Section and is currently under review.
3 FACILITY MODIFICATIONS AND PLANNED ACTIONS
The City has recently taken significant steps to improve the operations of the YWC. Actions include:
In Fall 2018 the City retained SCS Engineers to prepare an Operational Assessment of
the facility. The Assessment included; a facility overview, historic inbound recovered
product material, material balance and net quantities, current operations and
maintenance, proposed facility improvements, markets for recovered products,
regulatory compliance and recommendations. The Assessment outlined several
proposed facility improvements under the categories of site layout, material handling and
processing, stormwater and process water management, as well as regulatory
compliance. During the Assessment, SCS surveyed potential users of the stockpiled
material as well as the processed organic products from the YWC. The City has
subsequently retained SCS to assist with the implementation of many of the
recommendations.
In Fall 2019 the City retained R. Alexander and Associates, Inc. (RAA) to produce a
Compost Market Research and Planning Report (Marketing Plan) as guidance in the
sales and distribution of organic products produced at the YWC. During development of
the Marketing Plan, RAA surveyed potential users of the stockpiled material as well as
processed organic products from the YWC. The Marketing Plan contains both short term
and longer term active marketing strategies that are currently being considered and
implemented by the City.
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In addition, SCS is currently assisting the City with development of a Request for Qualifications (RFQ)
for the purpose of retaining a vendor (or vendors) for removal and transportation of the stockpiled
"legacy" material from the facility. Additional tasks SCS has been retained to perform are; assistance
with stockpile sampling and removal (this task is in process), Stormwater and Compost Facility
Permit support, masterplanning and surveying, stormwater system design, operational areas design,
SWPPP revisions and Operational Plan revisions.
Addressing NCDEQ Comments/Plan to Address Stockpiles
The following addresses each of the NCDEQ comments listed in the Facility Compliance Inspection
Report received by the City on February 25, 2020. The comments are listed in Section 3 above while
the City responses are stated below.
1. The City will remove the hardwood logs from the capped area of the LCID landfill on the north
side of the facility and repair any damage to the landfill cap. However, the City believes that
this area is designated as an operational area in its solid waste permit (Drawing Number G3)
and requests a review of the NCDEQ's interpretation so that operations may be performed in
this area in the future.
2. Stockpiled Material:
a. This Solid Waste Inspection Mitigation Plan (Revision 2) has been updated to include
how the City plans to address the three areas of stockpiled material and is being
submitted to NCDEQ within 30 days of receipt of the Inspection Report received February
25, 2020. An anticipated timeline is attached to this Plan as Exhibit 1.
b. The City anticipates that removal of the stockpiled material will occur through several
avenues;
• First, the City plans to retain a vendor (or vendors) through the RFQ process for
removal and transportation of the stockpiled material off -site. The City prefers
that stockpiled material be used for a beneficial purpose and anticipates that
potential vendors may propose additional processing of the material either at the
YWC (which the City is open to under certain conditions that conform to the
facility's Permit) or at an off -site location. Disposal at a landfill is the least
preferred option. The rate at which the stockpiled material will be removed by the
selected vendors will depend on the vendor's proposal and combination of
removal, treatment/processing, transportation and beneficial end use (or
disposal) steps and the individual methods for each.
• Second, implementation of the Marketing Plan through short and longer term
active marketing and proactive identification of potential users of the material
(outside of the RFQ process). The rate at which the stockpiled material will be
removed using the Marketing Plan's proposed strategies will depend on the
effectiveness of the strategies and overall market conditions. Based on recent
experience, the City believes that newly arrived material can be processed and
sold to the public at the equivalent rate that it is brought into the facility.
c. A Stockpile Sampling Results Report dated February 28, 2020, was submitted to the
NCDEQ on March 13, 2020.
d. The NCDEQ's comment that Stockpile 1 has been removed is noted.
e. The City anticipates that the remaining portions of the Unprocessed Leaf Stockpile will be
removed as described (in b.) above.
3. The City has addressed many of the stormwater ponding issues described in the Inspection
Report, although, several relatively small areas remain problematic so the City continues to
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address issues by filling and grading. As material is brought in and removed from the facility,
and material settlement occurs in various areas of the site, small, localized ponding will likely
remain an issue that the City will diligently address on a regular basis.
4. The access road into the facility (off New Hope Road), including all roads used by the
customers and the public, are paved and are therefore considered "all weather." The City
plans to make the access roads that connect to various processing areas, which are used by
site personnel at the facility "all weather" by providing proper drainage and construction
improvements through development of the "Master Plan and Surveying" task that SCS has
been retained to assist with. SCS will assist the City with the design of a Master Plan for the
facility which will address stormwater runoff and facility infrastructure resilience concerns. As
funding becomes available, the City plans to solicit bids from contractors for implementation
of design components. This process has just begun and is expected to last into 2021.
5. A topographic survey of the facility that documents elevations of each stockpile and
processing area was performed in January 2020. SCS used the survey results to estimate
the approximate volume (in CY) and weight (in Tons) of materials included in the total facility
capacity. Lower and upper density range estimates were used along with the calculated
volumes of material onsite (see Exhibit 2). A summary of the calculations is shown below.
Table 1. Volume and Weight Calculations
AREA
Legacy Stockpile
VOLUME Density
268,900
Lower
800
Density UpperUpper
1,100
107,560
147,895
Unprocessed Leaf
83,100
800
1,100
33,240
45,705
Add. Stockpile
44,700
500
625
11,175
13,969
Windrows
31,800
500
625
7,950
9,938
Surge Piles 1
13,100 1
500
1 625 1
3,275
1 4,094
Total I
I
1 1
163,200
1 221,600
6. The NCDEQ's comment that the City's renewal application is under review is noted.
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Exhibit 1. Anticipated Timeline
ID
Task
Mode
Task Name
Duration
start
Finish
1 st Half 2nd Ha
E 8 M E B M E B M E B M E B M E B M E B M E B M
1
Stockpile 53days Wed Fri2/29/20
sampling/volume 12/18/19
Determination
Stockpile Sampling 2 days Wed 12/18/1Thu 12/19/1
Sample Analyses 12 days Fri 12/20/19 Mon 1/6/20
AN, Surveying 5 days Mon 1/13/2C Fri 1/17/20
AL Stockpile Sampling 39 days Tue 1/7/20 Fri 2/28/20
Results Report
Request for 91 days Mon 3/2/20 Mon 7/6/20
Qualifications
;f RFQ Development 40 days Mon 3/2/20 Fri 4124120
A# RFQAdvertised 1 day Mon 4/27/2C Mon 4/27/2
Pre -Submittal 1 day Wed 5/6/20 Wed 5/6/20
Conference
2
3
4
5
6
1
7
8
9
ID
IT.sk
Mode
Task Name
Duration
Start
Finish
1H 2nd Ha
E 8 M E .`,MaE B M E B M F 8 M E 8 M E 8 M E B M
10
SOQs Due 1 day Mon 5/25/20Mon 5/25/2
SOQ Evaluation 10 days Tue 5/25/20 Mon 6/8/20
Selected Offerors 5 days Mon Fri 6/19/20
Presentations 6/15/20
* Selection of 1 day Mon Mon
Offeror(sE 6/22/20 6122/20
011, Awarding of 1 day Tue 6130/20 Tue 6/30/20
Contract(s)
Contract Start 1 day Mon 7/6/20 Mon 7/6)20
r
1
1
11
12
13
14
15
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Exhibit 2. Material Volumes
UNPROCESSED
LEAF
STOCKPILE
83,140 CY WINDROWS
31.800 OY
GENERAL NOTES:
I. vOLuMES BASED ON
SURVEY DATA PROVIDED
9Y TwT ON 1/16/2020.
2- BUMM OF STOCKPILE
ELEVATIONS BASED ON
TOPOGRAPHY SURROUNDING
STOCKPILE AREAS AlNO
SURGE PILES SUPPLEMENTED BY DATA
FROM BORINGS DRILLE3
13.100 CY �Q DURING SOIL SAMPLING,
�lV I WHERE AVAILABLE.
Q°
I t �
LEGACY
STOCKPILE
f r
268, '00 CY
C5
ADDI ONAL
STOCKPILE
44,7DO CY
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