HomeMy WebLinkAbout9230_INSP_20210225NORTH CAR()LINAD_E Q��
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FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
YW
Transfer
Compost
X
SLAS
COUNTY: WAKE
MSWLF
PERMIT NO.: 9230-CDLF-2014
Closed
HHW
White
Incin
T&P
FIRM
MSWLF
goods
9230-COMPOST-
FILE TYPE: COMPLIANCE
CDLF
X
TireT&P
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspection: February 25, 2021
FACILITY NAME AND ADDRESS:
Greenway Waste Solutions of Apex, LLC
5940 Old Smithfield Rd
Apex, NC 27539
GPS COORDINATES: 35.68632,-78.84364
FACILITY CONTACT NAME AND PHONE NUMBER:
Grant Kiser, Manager
919-367-2895
Grant@griffinbros.com
FACILITY CONTACT ADDRESS:
Greenway Waste Solutions of Apex, LLC
P.O. Box 699
Holly Springs, NC 27540-0699
PARTICIPANTS:
Davy Conners, NC DEQ — Solid Waste Section
Andrew Hammonds, NC DEQ — Solid Waste Section
Grant Kiser, Greenway Waste Solutions of Apex, LLC
Date of Last inspection: December 22, 2020
STATUS OF PERMIT:
A Permit to Operate Greenway Waste Solutions of Apex, LLC, permit numbers 9230-CDLF-2014 (Phase 1, 2, and 3) and
9230-COMPOST (Large Type 1), was issued on July 10, 2020 and February 21, 2020, respectively, and will expire on
December 10, 2062 and February 21, 2030, respectively.
PURPOSE OF SITE VISIT:
Complaint investigation: on December 1, 2020 Davy Conners received a phone call from Thad Valentine with the Division
of Energy, Mineral and Land Resources regarding lack of a DEMLR permit for the compost area at Greenway Waste and
organic leachate concerns.
CURRENT STATUS OF NOTICE OF VIOLATIONS SENT JANUARY 5, 2021:
A. Violation: 15A NCAC 13B .0542 (1)(4) Leachate must be contained on -site or treated prior to discharge.
An NPDES permit may be required prior to the discharge of leachate to surface waters.
Status: Unresolved. Griffin Brothers C&D Reclamation and Greenway Waste Solutions, LLC, parent company
of Greenway Waste Solutions of Apex, LLC, remain in violation of 15A NCAC 13B .0542 (l)(4) in that leachate
was still not being contained onsite at two of the fourpreviously noted C&DLF leachate releases. The following
describes the locations of the leachate releases, as seen in the December 22, 2020 inspection, and the status as
of the February 25, 2021 inspection.
Page 1 of 11
FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"-t0E'"�m"""°"""' Solid Waste Section
Leachate Release 1 (LR1) was located across a broad area along the northern side slope of the inactive C&DLF.
A map of the leachate releases can be found in the Leachate Release Sampling Plan submitted to the Section by
Greenway Waste Solutions of Apex on January 29, 2021. During the February 25, 2021 inspection, this release
was still flowing from the side slope, however it had been dammed with an earthen berm at the toe of the slope
to contain the leachate (Figures 1 and 2). A small area to the east of the berm was wet and flowing into Basin 4
(Figure 3). This substance needs to be investigated further to determine if it is leachate.
Leachate Release 2 (LR2) was located at the northwest corner of the inactive C&DLF, across the service road
from Basin 1. During the February 25, 2021 inspection, the leachate release was still flowing from the side slope,
however it had been dammed with an earthen berm at the toe of the slope (Figures 4). Basin 1 was discolored
and may have been contaminated with leachate, although no leachate was observed flowing into the basin during
the inspection (Figure 5).
Leachate Release 3 (LR3) was located on the southern side slope of the inactive C&DLF, across the service road
from Basin 3. During the February 25, 2021 inspection, leachate was actively flowing from this area into Basin
3 (Figures 6 and 7). Ms. Conners and Mr. Hammonds followed the flow of leachate from Basin 3 to a creek that
flows from east to west, just the south of the landfill (Figures 8 and 9).
Leachate Release 4 (LR4) was located on the southern side slope of the inactive C&DLF, just to the east of LR3.
During the February 25, 2021 inspection, leachate was flowing from this area into a ditch (Figure 10). The culvert
where the ditch flows under the road and into Basin 3 had been stopped with soil, but leachate was flowing
through the soil plug into Basin 3 where it merges with leachate from LR3 (Figure 11). As noted above, the
outflow of Basin 3 was flowing into a creek to the south of the landfill (Figure 8 and 9).
B. Violation: 15A NCAC 13B .1406 (4) Leachate shall be contained on site or treated prior to discharge. A
National Pollutant Discharge Elimination System (NPDES) permit may be required in accordance with
15A NCAC 02B prior to the discharge of leachate to surface waters.
Status: Unresolved. Griffin Brothers C&D Reclamation and Greenway Waste Solutions, LLC, parent company
of Greenway Waste Solutions of Apex, LLC, remain in violation of 15A NCAC 13B .1406 (4) in that organic
leachate was still not being contained onsite at one of the two previously noted organic leachate releases from
the composting operational areas. The following describes the locations of the organic leachate releases, as seen
in the December 22.2020 inspection, and the status as of the February 25, 2021 inspection:
Organic Leachate Release 1 (OLR1) was located at the Northwest Compost Area on both the south and north
edge of the compost area. During the February 25, 2021 inspection, a large volume of compost material had been
removed from this area (Figure 12). The amount of black organic leachate in the sediment basin seemed to be
less, based on the color, and Ms. Conners did not observe any organic leachate flowing into the basin.
Organic Leachate Release 2 (OLR2) was located at the East Compost Area. During the February 25, 2021
inspection, organic leachate was observed flowing from the compost area in the drainage ditch to the south of the
area, and into Basin 6A (Figure 13 and 14). Ms. Conners followed the flow of organic leachate from Basin 6A
to the same creek that LR3 and LR4 flow into (Figure 15).
CURRENT STATUS OF OBSERVED VIOLATIONS IN THE DECEMBER 22, 2020 INSPECTION REPORT:
A. Violation: 15A NCAC 13B .0542 (1) (2) Surface water must not be impounded over or in waste.
Status: Unresolved. During the February 25, 2021 inspection, surface water was still observed impounding over
the inactive C&DLF (Figure 16). Impounding water over waste was first noted as an issue in the October 29,
2020 inspection. A berm along the service road appeared to be trapping water on the top of the landfill and LCID
waste stored on top of the C&DLF was also causing water to pond.
Page 2 of 11
FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"' t0E'"�m"""°"""' Solid Waste Section
B. Violation: 15A NCAC 13B .1406 (3) Stormwater shall be diverted from the operations area.
Status: Unresolved. During the February 25, 2021 inspection, surface water was still observed ponding in the
operations area of the east compost area and the finished compost area (Figure 17). Stormwater ponding in
operations areas was first noted as an issue in the October 29, 2020 inspection.
OBSERVED VIOLATIONS:
A. 15A NCAC 13B .0542 (g) (3) Appropriate methods such as fencing and diking must be provided within the
area to confine solid waste which is subject to be blown by the wind. At the conclusion of each operating
day, all windblown material resulting from the operation must be collected and disposed of by the owner
and operator.
During the February 25, 2021 inspection, no methods were being used to contain windblown waste and large
amounts of wastes were observed along the side slopes of the C&DLF and in the finished compost area (Figure
18). Mr. Kiser said that a couple times a month he hires people to clean up windblown waste, however windblown
waste must be picked up daily. Windblown waste was noted as an issue in the December 22, 2020 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.
ADDITIONAL COMMENTS:
A. Windrow dimensions for active composting must be limited to a maximum of 6-feet high and 15-feet wide
unless otherwise approved by the Section. This issue was noted in the December 22, 2020 inspection for both
the northwest compost area and the east compost area. During the February 25, 2021 inspection, compost
windrows dimensions in the east compost area still did not meet these specifications; specifically, compost was
windrowed on top of an approximately 4 to 5 feet deep layer of compacted compost. Leachate was observed
ponding between the rows. This is likely one of the causes of the organic leachate release. Progress to resolve
this issue in the northwest compost area was well underway with the removal of the compost.
B. During the February 25, 2021 inspection, land clearing waste being stored on top of the inactive C&DLF
had water ponding in and around it. This issue was also noted in the October 29, 2020 and December 22, 2020
inspections. Additionally, the western portion of the top of the inactive C&DLF was overgrown with bushes
and trees (Figure 19). Mr. Kiser said he thinks the trees are growing on top of an old compost or soil pile
stored on top of the C&DLF, which is why that area had not been mowed for several years. The storage of
compost and land clearing waste on top of the landfill is likely contributing to the leachate releases on the inactive
C&DLF by restricting flow and impounding stormwater over waste.
C. The owners and operators of all C&DLF units must cover the solid waste with six inches of earthen material
when the waste disposal area exceeds one-half acre and at least once weekly. A berm along the top western
portion of the inactive C&DLF had exposed waste on it (Figure 20). This berm might also retain water and
contribute to the leachate problem. Additionally, the working face of the C&DLF appeared to be larger than half
an acre (Figure 21).
Page 3 of 11
FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"' t0E'"�m"""°"""' Solid Waste Section
D. Monitoring wells must be capped and locked. During the February 25, 2021 inspection, several of the well
heads were missing locks or the locks were not secured.
E. White goods must not be disposed of in a C&DLF and this facility is not permitted to process white goods.
During the inspection, the metal recycling area had white goods in it. Ensure that loads are being inspected and
reject waste that cannot be accepted at this facility.
F. 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, must be removed from the facility through sale, use,
or reuse by December 31 of the same year. A large amount of concrete for grinding has been stored at the
facility for what appears to be longer than a year. During the inspection, weeds were growing up through the
concrete material. Additionally, there was unacceptable waste comingled with the concrete, including some waste
that may have contained asbestos. Remove all unacceptable waste and grind this material within the appropriate
timeframe. It may be necessary to temporarily divert or dispose of the concrete within the C&DLF until grinder
is fully operational and the pile is more manageable.
CORRECTIVE ACTIONS:
The above listed notice of violations, observed violations, and compliance issues require the following corrective
actions to bring the site into compliance:
1. C&DLF Leachate Releases — Corrective Action Requirements
a. Soil and water samples must be taken according to the Sampling Requirements listed below in Corrective
Action 2. Submit the sampling plan and results to Elizabeth Werner, Hydrogeologist, 1646 Mail Service Center,
Raleigh, NC 27699-1646, elizabeth.wemer@ncdenr.gov, 919-707-8253 and Davy Conners, Environmental
Senior Specialist, davis.connersnncdenr.gov, 919-707-8290.
b. Samples must be taken in all areas that have been impacted by leachate from the C&DLF that are outside of the
landfill footprint, including ditches, sediment basins, or streams into which the pipe drains. Because this
inspection confirmed leachate flowing into the creek to the south of the landfill, water samples of that
creek are required.
c. Within 30 days of receiving this report, determine the underlying cause of each of the leachate releases from
the C&DLF and make repairs to resolve these causes. Specifically, but not limited to, the areas of impounded
water over waste on the inactive C&DLF must be repaired to shed water and the berms on top of the inactive
C&DLF should be evaluated to determine if they are necessary. Additionally, the land clearing waste and, if
present, the compost from on top of the inactive C&DLF should be removed to determine if there is impounded
water underneath these wastes.
C&DLF Leachate Releases — Sampling Requirements
a. Within 30 days of receiving this report, submit an updated Sampling Plan to include additional water samples
for Section approval prior to sampling. The proposed plan shall be submitted in electronic format sent via email
to Elizabeth Werner at elizabeth.werner&ncdenr.gov and Davy Conners at davis.connersnncdenr.gov and
must meet the following requirements:
• Include a map/aerial photo depicting area of impact and proposed sampling locations.
• Provide a description of the proposed sampling methodology.
• Describe proposed subsurface soil sampling and surface water sampling (if applicable) at specific
locations, including background soil and upstream water locations, to evaluate the extent of the potential
environmental impacts from the release(s) at the facility
i. Subsurface soil samples shall be collected between one to two feet below ground surface
ii. Discrete soil samples shall be collected. Composite samples will not be accepted
Page 4 of 11
FACILITY COMPLIANCE INSPECTION REPORT
D_E Q�� Division of Waste Management
NORTH CAROLINA
o"-t0E'"�m""lW'Ift Solid Waste Section
iii. All soil and surface water samples shall be analyzed by a NC certified laboratory for 40 CFR Part
258 Appendix I parameters (VOCs and Total Metals), total phosphorus, sulfate, nitrate, and pH.
b. After Solid Waste Section approval of the sampling plan, please implement the plan within seven days. Within
10 days after the analytical results are received from the laboratory, please submit documentation regarding the
sampling event which should include the following:
• A summary of the leachate release, actions taken to address the release, and the release assessment
• A map/aerial photo depicting the sampling locations
• A table of the surface water analytical results compared to the NCDWR Surface Water Quality
Standards & Protective Values
• A table of the subsurface soil analytical results compared to the NCDEQ Preliminary Soil Remediation
Goals (PSRGs). Both the Residential Health Based and the Protection of Groundwater PSRGs must be
met
• The associated laboratory reports from the NC certified laboratory including the chain of custody and
QA/QC results
• The sampling methodology, if different from the proposed plan
• Conclusions and recommendation
3. Organic Leachate Releases — Corrective Action Requirements
a. Within 30 days of receiving this report, determine the underlying cause of each of the organic leachate
releases from the compost areas and make repairs to resolve these causes. Specifically, but not limited to, the
compost operational areas must be repaired to shed water and compost must be windrowed as specified in the
rule.
4. Within 30 days of receiving this report, repair and regrade the inactive C&DLF such that it sheds surface water and
does not cause water to impound over waste.
5. Within 30 days of receiving this report, repair and regrade the compost operation areas such that the areas shed
surface water. Reconstruct compost into windrows to a maximum of 6-feet high and 15-feet wide without any
compost underneath these windrows. Make sure there is at least 25 feet between the compost area and swales and
berms and there are fire lanes on all sides of compost area. Measures to reduce or remove compost in the northwest
compost area and the east compost area should continue.
6. Immediately, begin picking up windblown waste at the close of business each day and return to the working face.
Within 15 days of receiving this report, begin implementing methods such as fencing to contain windblown waste.
7. Within 30 days of receiving this report, relocate the land clearing waste on top of the C&DLF and regrade the
landfill such that it sheds surface water. Additionally, remove the trees and bushes from the landfill and determine
the composition of the west edge of the inactive C&DLF. If it is compost, remove this from the top of the landfill.
Should Greenway Waste Solutions want to continue using the inactive C&DLF for storage of this material, you must
contact the Permitting Branch to seek approval.
8. Within 30 days or receiving this report, cover all waste on the berm of the inactive C&DLF with at least 6 inches
of earthen material. Determine if this berm is retaining water over waste and if so, regrade to promote positive
drainage. Additionally, ensure the entire working face is covered with earthen material when it gets larger than one
half acre or at least once a week.
9. Additionally, yard waste and yard trash were observed dumped along the facility access roads outside approved areas
during this inspection due road conditions and work to get the site into compliance. It may be necessary to temporarily
divert YW from your facility if you don't have storage capacity. Changes to storage and operations areas should be
submitted to the Section for approval before commencing.
Page 5 of 11
NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Attachment 1 contains photos taken during the February 25, 2021 inspection. Please contact me if you have any questions
or concerns regarding this inspection report.
Davy Digitally signed by
Davy Conners
S Date: 2021.03.09
Con ner
20:26:20-05'00'
Davy Conners
Environmental Senior Specialist
Regional Representative
Phone: (919) 707-8290 (o); (919) 621-3685 (c)
Sent on: March 10, 2021 X Email Hand delivery US Mail Certified No. f j
Copies: Ed Mussler, Section Chief— Solid Waste Section
Jason Watkins, Field Operations Branch Head — Solid Waste Section
Sherri Stanley, Permitting Branch Head — Solid Waste Section
Adam Ulishney, Environmental Compliance Branch Head — Solid Waste Section
Andrew Hammonds, Eastern District Supervisor — Solid Waste Section
Elizabeth Werner, Hydrogeologist — Solid Waste Section
Jessica Montie, Compliance Officer — Solid Waste Section
Amanda Thompson, Environmental Senior Specialist — Solid Waste Section
Thad Valentine, Environmental Senior Specialist — Division of Energy, Mineral, and Land Resources
Stephanie Goss, Environmental Specialist — Division of Water Resources
Page 6 of 11
NORTH CAR()LINAD_E Q��
OepaNnent of Envieonm,nbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Attachment 1: Inspection Photos
Taken by Daw Conners and Andrew Hammonds on Fe
Figure 1: LR1 dammed by earthen berm.
Figure 3: Area to the east of LR1 flowing into ditch and
sediment basin.
25, 2021
2: LR1.
� :y—„ �.sini�1*�'.,"iK` rblr Lr rr•Y
y � I
1tt1
i
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Figure 4: LR2 dammed by earthen berm.
Page 7 of 11
NOR;T CA�INA
OepaNmenf of Environmental0uali�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
yAT
y 4
' 4
Figure 5: Basin 1, across from LR2, was discolored and
may have been contaminated with leachate.
Figure 6: LR3 flowing into ditch.
Pop
r we
Figure 7: Basin 3 with leachate from LR3 and LR4
flowing into it.
r�.
Figure 8: Outflow of Basin 3 contaminated with leachate
from LR3 and LR4.
Page 8 of 11
NORTH CAR()LINAD_E Q��
OepnNnent of Environmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
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Figure 9: The leachate from outflow of Basin 3 (on right)
Figure 10: LR4 flowing into ditch with soil plug.
flowin into creek on left).
Figure 11: LR4 flowing through the soil plug into Basin 3.
Figure 12: The NW Compost Area with most of the
compost removed.
h.�
Figure 13: OLR2.
Figure 14: OLR2 flowing into Basin 6A.
Page 9 of 11
NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Figure 15: Organic leachate from OLR2 (on right) flowing
into the creek to the south of the landfill (on left).
r
Figure 17: Water ponding in and around compost
Merational area.
19: Trees on top of landfill.
Figure 16: Water ponding ontop of inactive C&DLF.
Figure 18: Windblown waste in Basin 6.
20: Berm on inactive C&DLF with exposed waste.
Page 10 of 11
NORTH CAR()LINAD_E Q��
OepaNnent of Envieonmenbl Wel�
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Figure 21: Working face of C&DLF appears to be larger
than half acre.
Page 11 of 11