SWC3613_INSP_20201229

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 6

UNIT TYPE:
Lined MSWLF LCID YW Transfer Compost X SLAS COUNTY: Gaston
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: SWC-36-13
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 12/29/2020 Date of Last Inspection: 07/02/2020
FACILITY NAME AND ADDRESS: WRE- EARTH FARMS, LLC COMPOST FACILITY 351 Colt Thornburg Road Dallas NC 28034
GPS COORDINATES: N: 35.36151° E: -81.16931°
FACILITY CONTACT INFORMATION:
Name: Michael Marlowe Address: 351 Colt Thornburg Road
Dallas NC 28034 Telephone: [phone]
Email address: [e-mail]
PARTICIPANTS: Jeffrey Bullard DWM, Michael Marlowe (WRE) STATUS OF PERMIT: Active EXPIRES: March 16, 2022
PURPOSE OF SITE VISIT: Routine
STATUS OF PAST NOTED VIOLATIONS: During the last inspection conducted on 07/02/2020
violations of the Conditions of Operating Permit were observed. Observed violations were cited for ponding of leachate and stormwater on permitted compost area in violation of the Conditions of Operating Permit (7).
OBSERVED VIOLATIONS: During the site inspection conducted on 12/29/2020 violations of the NC Solid Waste rules below were
observed.
15A NCAC 13B .0203(d) By receiving solid waste at a permitted facility, the permittee(s) shall be considered to have accepted the conditions of the permit and shall comply with the conditions of the permit.
Conditions of Operating Permit (3) A sign must be maintained at the site entrance providing site
information including the permit number, prohibited materials, and emergency contact information. 15A NCAC 13B .1406(9) Sign Requirements. (a)Signs providing information on waste that may be received, dumping procedures, the hours during which
the site is open for public use, and the permit number shall be posted at the site entrance.
(b)Traffic signs and markers shall be provided to direct traffic to and from the discharge area.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 6

(c)Signs shall be posted stating that no hazardous waste, asbestos containing waste, or medical waste may be
received at the site. Observed violations of the above stated rules were cited where required signage posted at the entrance to the facility did not include prohibited materials, and emergency contact information, the facility permit number
posted at the entrance did not match the current permit number on file.
Conditions of Operating Permit (7) An appropriate Division of Energy, Mineral and Land Resources
(DEMLR) permit for managing any stormwater or wastewater at the facility must be maintained as required. Any leachate generated at the facility and any runoff from the facility must be managed to prevent contamination of groundwater and surface water. The facility must be maintained to prevent the accumulation
of stormwater and leachate on processing areas, composting areas, storage areas, and roads. Conditions of Operating Permit (24) Facility construction, operations or practices must not cause or result in
a discharge of pollution, dredged material, and/or fill material into waters of the state in violation of the requirements under Sections 401 and 404 of the Clean Water Act, as amended. A Notice of Violation was issued for violations of conditions 7 and 24 stated above, where during the site
inspection on 12/29/2020, extensive ponding of leachate and stormwater was observed on several areas of the
compost windrow and processing areas. Violations of the above stated rules were also observed in two areas along the northeastern boundary of the permitted compost area where the facility is bounded by the S. Fork Catawba River. At area 1, leachate was observed flowing downslope from the base of newly formed windrows, exiting the boundaries of the permitted site. The leachate was following established drainage patterns that
terminated at a headcut on the bank of the S. Fork Catawba River. At the time of this inspection leachate was
observed ponding in depressional areas and infiltrating into the ground surface approximately 20 feet from the bank of the river. While no leachate was observed flowing directly into the river, the presence of drainage patterns leading to the river and head cutting there suggest discharges directly to surface waters do occur during rainfall events that produce sufficient amounts of runoff and flooding. At area 2 located approximately 200 ft to the northwest from area 1 described above, a drainageway was observed beginning at a breach in a containment berm downslope from the permitted compost windrow area. The drainageway was oriented downslope toward the S. Fork Catawba River. The drainage feature appeared
to have been constructed to provide drainage for portions of the compost windrow area upslope of the berm
that drain to that location. At this same location during a previous inspection on 07/02/2020, ponding of leachate and storm water was observed above the berm where the mouth of the drainage feature has been established. At the time of the inspection no appreciable flow was observed leaving the permitted area in this location however, the presence of indicators such as standing water, drainage patterns, scouring and alluvial
deposits indicate that in the past stormwater and leachate has been discharged from the permitted site into the
floodplain of the S. Fork Catawba River. Under flooded or saturated conditions and /or during rain events that produce sufficient runoff; discharges of storm water and leachate to surface waters occur with this devise in place given the proximity of the floodplain and frequency of flooding in this area. 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

Page 3 of 6

ADDITIONAL COMMENTS
1. The facility is currently permitted as a large, type 3 solid waste compost facility. 2. The required 100-foot buffer between the composting area and the property boundary appears to be maintained.
3. Required records of compost temperatures and laboratory analysis were made available for inspection and
appeared to be current. 4. No objectionable odor was detected beyond the facility boundary during the inspection. 5. Access to the facility is secured with a lockable gate. 6. The main access road to the facility was of all-weather construction and well maintained. Some interior
roads were ponded by storm water but appeared passable. (See Observed Violation on page 1 of this report)
7. Signage was displayed at the entrance to the site. Signs did not include prohibited materials or emergency contact information. (Please see Observed Violations on page 1 of this report) 8. Approved setbacks to property lines appear to be maintained. 9. Established windrows appeared to be sufficiently spaced to allow access for firefighting equipment.
10. A Notice of Violation was issued for accumulation of stormwater and leachate on processing areas and for
operations or practices resulting in a discharge of pollution into waters of the state. (See Observed Violations on page 1 of this report) 11. Two flexible suction type hoses where found buried in the bank of the river where the ends of the hoses exposed by erosion, were submerged in the river. The other ends of the hoses were buried in the bank,
oriented NE to SW in the direction of the compost facility upslope. The purpose of the hoses was unknown.

Aerial photo of compost facility
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 6

Signage presented at entrance of facility.
Grease septage residue in depressional areas in buffer area east of facility.
Ponding of leachate and stormwater on compost processing and windrow area. Photo at top right shows leachate
migrating downslope toward river hidden in treeline.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 5 of 6

Looking upslope from buffer east of composting area. Leachate ponding in depressional areas. (Bottom right) erosional feature in riverbank immediately downslope where runoff drains from this area during storm events.
Conveyance established at opening in berm draining part of compost windrow area into buffer area and floodplain adjacent to river.
Hoses exposed by erosion buried in riverbank east of facility downslope from ponded leachate.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 6

The observed violations described above require corrective actions be made. Please review the sign
requirements for this facility detailed in the Conditions of Operating Permit and 15A NCAC 13B .1406 Operational Requirements for Solid Waste Compost Facilities and make corrections as needed to bring facility sign requirements into compliance with Solid Waste rules. Please refer to the Notice of Violation that accompanies this report for details and corrective actions required for violations related to stormwater and
leachate issues noted in this report.
In addition to the corrective actions required above, more information is needed regarding the purpose and origin of the hoses buried in the bank of the river pictured above. Confirmation needs to be made if these hoses connect to or are used in relation to any permitted process or activity on this site. Please verify in
writing the purpose of the hoses, whether they are connected to or are used in relation to any of the permitted
facilities operated by WRE and an approximate date they were installed. This information can be sent by email to [e-mail] or mailed to: Jeffrey Bullard
Environmental Specialist II
Division of Waste Management-Solid Waste Section 1646 mail service center Raleigh, NC 27699-1646
Please contact me if you have any questions or concerns regarding this inspection report.

____________________________________________ Phone: [phone] .
Jeffrey Bullard, Environmental Specialist II Division of Waste Management, NCDEQ Regional Representative

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