2610COMPOST2011_INSP_20201117

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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UNIT TYPE:
Lined
MSWLF LCID X YW X Transfer Compost X SLAS COUNTY: Cumberland
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: 2610-Compost-2011
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: November 17, 2020 Date of Last Inspection: May 16, 2018

FACILITY NAME AND ADDRESS:
Wilkes Road Yard Waste Facility
779 Wilkes Road
Fayetteville, North Carolina
GPS COORDINATES: Lat.: 35.024923 Long.: -78.875782
FACILITY CONTACT NAME AND PHONE NUMBER:
Amanda Bader, SW Director, CCSW
Tim Middleton, Facility Supervisor, CCSW
[e-mail]
910-321-6835 FACILITY CONTACT ADDRESS: Office of Solid Waste,
698 Ann Street,
Fayetteville, NC 28301

PARTICIPANTS: Amanda Bader, CCSW Tim Middleton, CCSW Neil Cunnington, CCSW
David Powell NCDEQ, SWS
STATUS OF PERMIT: Permit to Operate, T&P July 24, 2006; Permit to Operate, Compost Type 1 June 9, 2015; Expired June 9, 2020 SUMBIT RENEWAL APPLICATION.
LCID landfill Closure was certified in 2010, reference Doc ID 14561. Storage of wood and mulch
material is approved for 0.56-acres operation on top of the closed landfill. (Composting is not approved on top of the
closed landfill.)
PURPOSE OF SITE VISIT: Comprehensive Inspection
STATUS OF PAST NOTED VIOLATIONS: RESOLVED - 15A NCAC 13B .0566 OPERATIONAL REQ. FOR LAND CLEARING/INERT DEBRIS (LCID) LANDFILLS Land Clearing and Inert Debris (LCID) landfills shall meet the following operational requirements:
(1) Operational plans shall be approved and followed as specified for the facility.

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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Weight ticket documentation was given during inspection to show material was removed and disposed of at Ann St facility. No material currently atop Closed LCIDLF and vegetation established. Couple small shrubs/trees need removal. Good Job. RESOLVED - 15A NCAC 13B .0203 PERMIT APPROVAL OR DENIAL (d), 15A NCAC 13B .1406 OPERATIONAL REQUIREMENTS FOR SOLID WASTE COMPOST FACILITIES (1), and Permit Conditions, Part 1 (9), (17) and (19). No material currently atop Closed LCIDLF. Good Job. EOW markers need to be improved and vehicles moved from edge of slope on Closed LCIDLF. OBSERVED VIOLATIONS: N/A

ADDITIONAL COMMENTS:
1. David Powell met with Amanda Bader, Tim Middleton, and Neil Cunnington with Cumberland County to inspect Wilkes road Compost facility.

2. Facility is secured by a gate. Odor was not an issue during inspection.

Entrance of facility at scale house.

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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3. Tim Middleton completed Composting Councils Compost Operators Training Course. Be sure and have trained operators onsite when operating.
2015 Permit, Attachment 3, Part I, 4. - A responsible individual trained in facility operations must be onsite during all operating hours of the facility, in accordance with NCGS 130A-309.25.
Ms. Bader forwarded this picture of compost certificate for Mr. Middleton

4. David Powell and County staff walked perimeter of closed out LCID LF. In recent years, it was being used to store large amounts of processed material, which was beyond what was originally approved, and that material is
now gone. It was a large undertaking having all this material removed properly and reestablishing vegetation atop the LF. Good job. Bulldozer, trailer, truck, and a broken down grinder are being stored atop the closed LCIDLF. These items must be removed to outside of EOW. County has new horizontal grinder, that makes 2 and a third one that is going to be sold, and a Morebark6600, older one is 6400 model.
Looking west atop closed LCID. Looking east along back.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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Vehicles and broken equipment are not approved to be parked or stored atop closed LCIDLF. Move all vehicles to outside edge of waste. Discussions onsite included some of this equipment being sold soon. Equipment needs moving ASAP.
5. There was a couple shrubs/trees that need to be removed in back on north side. EOW markers were not visible during inspection, but they were present it seems. County staff showed David Powell pictures while county staff
were at another site at same time, they were just very short and overgrown with vegetation. Obviously, this need addressing. David Powell suggested larger white PVC pipes that could be seen easily and mowing the perimeter frequent enough that they could remain visible anytime. This also shows staff were edge of waste is to inspect for issues such as erosion and leachate releases. This should be a priority of management of this LF.

6. Loading and staging area for finished composted material, between closed out LCIDLF and scale house, had some water ponded around the stockpile. It had recently rained a lot, but this area needs to be built up more to shed storm water so does not pond around compost product.

7. Current operations area in center of facility behind scale house. Material is brought in, screened and anything over 3 inches goes to one of two boilers. Canal Wood in Lumberton or Mr. Mulch will haul it to Florence SC.
Smaller material is composted, time and temp records kept, then finished product sold to public or goes to Ann St LF for mixing 50/50 with soil for ADC. Time and temp records sent via email after inspection, were in good order.
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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This view also shows the ditch that runs through center of processing and windrow storage area.

8. Windrow storage areas need grading/sloping to address ponding water and prevent leachate from being released to the environment.

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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9. During the inspection, roads were in somewhat good shape except toward the east from scale house. No glass was visible in roadway. Within past week, there has been ~ 25 years 24-hour storm in some areas, so area was still wet with some standing water onsite. Cumberland County staff indicated they suspect a culvert in the ditch
along this access road/path toward the east may be crushed and is making it difficult for storm water to flow as designed. The County also indicated that the east outfall is being backed up by either beavers or clogged drainage near 87. Either way, the County needs to fix the drainage issues immediately. If this can be managed properly then a buffer of 25 feet from windrows can be maintained as required by permit. Otherwise it would be a 50 ft.,
which there is not room to maintain that much and still operate at same level and then there would still be standing water issues which would cause noncompliance.
David Powell suggested cleaning out ditches, adding some additional footage to the buffer and vegetating the area with seasonal grasses to utilize nutrients and reduce any erosion of material during rain events. Cleaning out the ditch and allowing for proper storm water flow off site may open the facility up to a potentially bad compliance
situation if there is leachate present in the future and it flows into the ditches, then it would fast track it to runoff and potentially discharge. “Any leachate generated at the facility and any runoff from the facility must be managed in such a manner that ground or surface water quality will not be adversely affected.” Water control structures may be needed to give the facility a mechanism in stopping any leachate from leaving site. So, with that said,
management of the ditches, buffer areas and operating the compost windrows will need to be paramount, as already should be, to minimize this potential. Water coming into contact with waste material and soaking into ground may cause future problems with groundwater and the county may be required to install wells and sample.
David Powell spoke with Mike Lawyer (with DEMLR) later that day on the facility storm water issues. It seems DEMLR agrees with cleaning out the ditches, managing the buffers and adding good vegetation those areas and addressing the reason water is being backed up onto property from the outfall near 87. DEMLR has required the site to increase sampling currently. The County will need to communicate with DEMLR on their requirements and improvements to ensure compliance and addressing any issues.

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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Looking south in center of facility operations and storage. East outfall is to the left. This is a ditch that has become backed up with sediment and become somewhat of a swampy area. Ditch
should be managed and be sure material stored or processed on each side meets 25 ft. buffer. Currently the 25 ft. buffer is being met. 10. Although there has been considerable progress on removing recent years’ accumulation of yard waste from storms
and hurricanes, there is still older mulch onsite. This facility is not permitted or designed for material to come in and stay. East side of facility has mulch material stored onsite. There is also some along southern side near the ditch that needs fixing. Given its age and viewing it onsite, there may not be much “composting energy” left to meet 1400 rules for giving this material to the public. While onsite County staff indicated that they are slowly
mixing it in with new material to elevate this issue. The county shall submit an Action Plan, within 30 days
of receiving this inspection report, addressing the removal of all these older stockpiles onsite. All material shall be removed within 6 months This can be mixed with soil for ADC at landfill or disposed of in landfill or used around county such as for beautification in flower beds etc. Reminder, it must meet 1400 rules if given to public or ends up with the public. The county MUST reduce the amount it accepts at this facility and divert it to other facilities that can manage it to help expedite this process. Contact Donna Wilson if need assistance meeting rule requirements and additional sampling options for the older material. (919-707-8255 or [e-mail]).
FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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11. Permit was available onsite along with certificates of operator training, fire notification reports, recent inspection reports, facility annual reports and monthly material analysis reports. Time and temperature records were emailed after inspection and were in order. Hilco was hired to remove material from closed LCIDLF. Reports were given showing the material atop the closed LCIDLF being taken to Ann St LF facility as requested. Dates ranged from 1/17/19 through 3/27/19. Good job.

FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section

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12. Permit renewal will likely not be allowed to increase capacity given the issues the facility already faces. Ms. Bader stated she had been searching for new site to permit that would meet requirements and showed some potential areas while onsite. This is proactive and it is a good thing to be looking at future needs. Ms. Bader indicated the bulk of yard waste material comes from City of Fayetteville. Currently the Wilkes Road Facility is permitted for 31,400 cubic yards. This condition is misleading. Much material that is brought in is screened then leaves to be boiler fuel. Onsite discussions that continued through email after inspection determined a total of 36,350 tons were received, with 18,620 tons composted and 26,563 tons left as boiler fuel. These figures account
for older material being slowly worked into the “mix” from July 2019 through June 2020. The permit capacity addresses max volume allowed on site at a point in time and not necessarily total volumes the facility can have over the course of a year. Even so, the facility has been overwhelmed in very recent years due to storms and an influx of more waste than it was designed for and material is still present which much be addressed soon. These
factors should be worked out in the permit renewal. Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] _ David Powell Environmental Senior Specialist Regional Representative

Sent on: November 25, 2020 X Email Hand delivery US Mail Certified No. [ _]
Copies: Jason Watkins, Field Operations Branch Head – Solid Waste Section Drew Hammonds, Eastern District Supervisor - Solid Waste Section Benjamin Jackson, Engineering Project Manager – Solid Waste Section Donna Wilson, Engineering Project Manager - Solid Waste Section Sherri Stanley, Permitting Branch Supervisor - Solid Waste Section Mike Lawyer, Environmental Program Consultant – DEMLR FRO