SWC-11-12 101011 RES

11
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
UNIT TYPE:
Lined
LCID
I
YW
Transfer
Compost
X
SLAS
COUNTY: BUNCOMBE
MSWLF
Lg III
PERMIT NO.: 11-12 SWC
Closed
HI-fW
White
Incin
T&P
FIRM
MSWLF
goods
FILE TYPE: COMPLIANCE
CDLF
TireT&P
Tire
Industrial
DEMO
SDTF
Collection
Monofill
Landfill
Date of Site Inspections: 10/07/11 & 10/10/11
FACILITY NAME AND ADDRESS:
Crowell Farms, Inc.
523 Pond Road
Asheville, NC 28806
Date of Last Inspection: 08/18/11
GPS COORDINATES: N: 35.538967 E:-82.618917
FACILITY CONTACT NAME AND PHONE NUMBER:
Name: Mike Crowell
Telephone: [phone]
Cell: [phone]
PARTICIPANTS:
Andrea Keller, NCDENR Solid Waste Section (SWS)
Michael Crowell, Crowell Farms, Inc. (10/10/11)
STATUS OF PERMIT:
Initial PTO - January 19, 2007
Permit is expired (in renewal process)
Large Type III Compost
PURPOSE OF SITE VISIT:
Partial site inspection — Complaint Investigation
STATUS OF PAST NOTED VIOLATIONS:
RESOLVED: 15A NCAC 13B .1406 (6): A site shall only accept those solid wastes that it is permitted to receive.
RESOLVED: 15A NCAC 13B .1406 (14)(A): The finished product shall meet the classification and distribution
requirements outlined in Rule .1407 of this Section.
OBSERVED VIOLATIONS:
None
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 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.
Phone: [phone] FAX: [phone] Internet: http://Portal.ncdenr.org/web/wm/sw
An Equal Opportunity 1 Affirmative Action Employer
NothCarohna
naturally

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 2 of 3
ADDITONAL COMMENTS
1. September 16, 2011 — Compliance documentation
As required per the September 2, 2011 Notice of Violation:
By September 16, 2011, Crowell Farms shall submit a written certification outlining the amounts of product
distributed, including information on all customers who received this material, between the spring 2010
sampling event (last sample which met pathogen reduction requirements) and the August 8, 2011 sampling
event. This submittal should include written certification of any actions taken to prevent the noted
deficiencies, including the intake of non permitted wastes, from occurring in the future. Mail this
certification to Andrea Keller, Asheville Regional Office, 2090 US Hwy 70, Swannanoa, NC 28778 by the
noted compliance date.
As the required written certification was received at the Asheville Regional Office on September 16, 2011 the
NOV for 15A NCAC 13B .1406 (6) is considered resolved.
2. October 7, 2011 — Site Inspection (partial)
On site for partial site inspection — primary purpose of visit was to coordinate with a Septage Management
Firm for a truck inspection. It appeared as though several windrows near the upper bins had been moved into
"active" composting windrows. Mr. Crowell was not on site during the visit. No issues were noted and odors
at the bin locations were of average/normal intensity.
3. October 10, 2011 —Site Inspection (odor complaints)
The most recent complaints received by the Section (10/7 through 10/10) were investigated. Odor intensity
levels were noted at the source (the facility) and in the neighborhoods adjacent to the facility property.
Normal levels (on the typical Air Quality intensity rating system of 1-5) of odors were noted at the facility.
The farm operations that are governed under the WNC Regional Air Quality program had a moderate level of
odor intensity resulting from the cattle feed operation, but no high intensity (4 or greater) levels were noted.
While there were odors on site, they were typical of operations — specifically as the facility was actively
moving windrows and bin materials at the time of the visit. No odors were noted off site (in the surrounding
neighborhoods) at any location, including at the entrance to the property, during the 10/10 inspection. After
speaking with Mr. Crowell (facility operator and owner), it appeared as though the odors noted in the
complaints may have correlated with the movement of compost materials from a storage bin into a windrow
formation, which occurred on Friday afternoon (10/7). The improved management of materials at the facility
had, over the previous 6 months or so, decreased the number and intensity of the complaints. The Section
will be reviewing an updated Odor Management Plan when the facility submits its full permit renewal
application. This Plan is expected to address specific best management practices to decrease odors during
facility operations.
4. October 13, 2011 — Compliance documentation
As required per the September 2, 2011 Notice of Violation:
By October 16, 2011, Crowell Farms shall provide a written Standard Operating Procedure (SOP) which
outlines analytical testing procedures, including, but not limited to, the following:
Sampling requirements and excedance limits for all tested constituents;
Sampling procedures for the pathogen test, foreign matter test, and for the regulated metals;
Response plan, including notification to the Section and halting distribution to the public of all

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section
Page 3 of 3
compost product, to be followed if/when lab results indicate a failed sample; and
Procedure for handing failed compost (re -composting, proper disposal, etc.).
This SOP should be incorporated into the Operations Plan submitted during the permit renewal
process. Mail this certification to Andrea Keller, Asheville Regional Office, 2090 US Hwy 70,
Swannanoa, NC 28778 by the noted compliance date.
The required SOP was received at the Asheville Regional Office on October 13, 2011. This SOP will be
reviewed by the Compost & Land Application Permitting department as part of the permit renewal process.
However, at this time it appears as though the SOP meets the requirements stated above and as such, the NOV
for 15A NCAC 13B .1406 (14)(A) is considered resolved.
In conjunction with the resolution of this Violation, and due to the potential public health issues associated
with the failure to meet the minimum pathogen reduction requirements, the facility is required to follow up
the verbal notification to customers (who received product generated during the time period in question) with
a written statement which contains the following information:
a. A statement regarding the failure of the compost product to meet minimum pathogen reduction
requirements for Grade A compost;
b. The time frame in which the facility produced/sold product which failed to meet the pathogen
reduction requirements;
c. Options for how to manage any "failed" product remaining with any customers (ex.: disposal at
landfill, returning product to facility, etc.).
It is understood that at this time, the facility is in the process of submitting for a permit renewal with the Solid Waste
Section (for the compost operation). This submittal will contain an Odor Management Plan to address several of the
issues noted (items 1 and 2). Please continue to keep the Section informed as to the status of the Aquifer Protection
and Division of Water Quality permits required as part of the Solid Waste Section permit approval process.
Please contact me if you have any questions or concerns regarding this inspection report.
Phone: [phone]
Andrea Keller
Environmental Senior Specialist
Regional Representative
Sent on: October
Email:
Hand
US
Certified No.
21, 2011
delivery:
Mail
ec: Michael Scott, Section Chief — Solid Waste Section
Mark Poindexter, Field Operations Branch Head — Solid Waste Section
Jason Watkins, Western District Supervisor — Solid Waste Section
Shawn McKee, Compliance Officer — Solid Waste Section