1905_INSP_20220405

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 4
1UNIT TYPE:
Lined MSWLF LCID YW Transfer Compost X SLAS COUNTY: Chatham
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 19-05
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: April 5, 2022 Date of Last Inspection: March 17, 2021
FACILITY NAME AND ADDRESS: Brooks Compost Facility – Large Type 3 Solid Waste Compost Facility 1195 Beal Road Goldston, NC 27252 GPS COORDINATES: Lat.: 35.54431 Long.: -79.36780 FACILITY CONTACT NAME AND PHONE NUMBER: Amy Fulford, Assistant Facility Manager – Brooks Contractor
w. 919-837-5914 f. 919-837-5097 c. 919-842-6063
[e-mail] www.brookscontractor.com FACILITY CONTACT ADDRESS:
Brooks Contractor Amy Fulford, Assistant Facility Manager
1195 Beal Road
Goldston, NC 27252
PARTICIPANTS: Chuck Kirchner, Environmental Senior Specialist – Solid Waste Section (SWS)
Amy Fulford, Assistant Facility Manager – Brooks Contractor Alan Brooks, Site Manager – Brooks Contractor AJ Brooks, Data Analyst and Windrow Manager – Brooks Contractor
STATUS OF PERMIT:
Permit to Operate (PTO) issued August 20, 2015 PTO expiration date January 22, 2020 Application for Permit Renewal Received by Solid Waste Section on September 27, 2019 PURPOSE OF SITE VISIT:
Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS:
None OBSERVED VIOLATIONS: None
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 4
ADDITIONAL COMMENTS
On April 5, 2022, Chuck Kirchner met with Amy Fulford, AJ Brooks and Alan Brooks to conduct a comprehensive inspection of the Brooks Compost Facility – Large Type 3 Solid Waste Compost Facility on Beal Road in Goldston,
Chatham County.
1. The facility is a Large Type 3 Solid Waste Compost (SWC) Facility. It produces compost from eggshell/hatchery waste, food waste (pre-consumer and post-consumer), yard waste (primarily leaves), wood mulch, animal bedding, grease trap waste, etc. (see facility operations & maintenance manual pages 6 and 7) and additional materials as approved by the Solid Waste Section (SWS).
2. Changes requested in the permit renewal include an area set up for an aerated static pile, an increase in tonnage from 75,000 tons to 100,000 tons max capacity annually and the inclusion of OFFAL poultry material.
3. The facility is in operation Monday through Friday 7:00 am to 5:00 pm and Saturday 8:00 am to 12:00 pm. 4. The facility permit, site plan, and operations plan were discussed. 5. Compost produced is primarily sold to construction and landscape contractors, farmers, and landscape
supply businesses. 6. Compost produced may be mixed with sand, pine bark fines, PermaTill, or per individual custom blend formula. 7. Upon receipt, liquid material is dumped into a mixing and bulking pit. Bulking agents are added to the liquid material and the material is mixed. 8. The mixture is then placed on an adjacent concrete pad to drain.
9. Leachate from the concrete pit and/or pad is re-mixed with additional bulking agents and added to the active windrows. 10. A large pile of horse manure bulking agent was observed adjacent to the concrete mixing area during this
inspection. 11. Food waste, grease trap waste and some eggshell waste compose most of the waste material that has a more liquid consistency according to Mr. Alan Brooks.
12. Eggshell/hatchery waste is placed in windrows upon receipt. It is mixed with bulking materials as the windrow is constructed. A layer of uncured compost is placed atop the windrow during its construction. 13. The facility commonly uses leaves, cardboard, mulch, animal bedding, horse manure and yard waste as bulking material. 14. Mr. Brooks stated that the facility receives leaves during the leaf collection season from the Town of Cary and
the Town of Siler City. 15. Active windrows are organized into two separate operational areas: eggshell/hatchery waste and food waste. 16. Windrows that contain eggshell/hatchery waste are in the upper rows and the food waste windrows are in the lower rows on site. 17. During the inspection there were 16 windrows observed in the upper windrow section and 13 windrows in the lower windrow section. 18. Brooks Composting has purchased a Scarab Compost Turner to turn windrows. Alan Brooks stated that the compost turner is able to make the windrows larger and has greatly increased the efficiency of turning the windrows. 19. Three curing stockpiles were observed during this inspection. Curing pile 1 & 2 contain eggshell/hatchery compost and curing pile 3 is from the food waste compost. 20. A small stockpile of NOP (National Organic Program) compost was also observed near the curing piles. 21. Runoff from the windrow areas goes into a leachate pond located at the southeast corner of the windrows. The leachate is pumped-out and used to irrigate active windrows in the first 30-50 days of the windrow.
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 4

22. Active windrows appeared to be within required dimensions and had the required spacing between windrows. 23. Active windrows are commonly maintained for 120-150 days during which time the process to further reduce pathogens (PFRP) is met. Windrows that have met PFRP are combined into a curing pile. Material
is generally cured for an additional 6 to 12 months. 24. Stockpiled curing material/compost is limited to a height of 60 feet. Curing stockpiles appeared to be approximately 25 feet in height during this inspection.
25. Compost is screened prior to sale. Screening rejects are separated into a few different piles. Small rocks are used for road bedding, compost rejects are recycled into the active windrows, some wastes like plastic are separated into a windsock below the screener. When the windsock is full it is tied off and the whole sock is taken to a landfill according to Mr. Brooks. Any larger rocks are also separated and taken to a landfill. 26. Rock screenings observed on site were in small piles and windsock appeared to be about half full during this inspection.
27. The facility annual report (FAR) dated August 1, 2021 was received by the SWS. Material received for July 2020 through June 2021 is 46,406.40 tons. The amount of compost created is 29,275.51 tons, the amount sold/given- away is 33,765.55 tons, and no amount was stockpiled on site. 28. The facility maintains records of the quantity, type, and source of material received for processing. The amount of material received from January 1, 2021 through December 31, 2021 is 50,217.20 tons. The amount of material sold is 20,336.7 tons according to Mr. AJ Brooks. 29. The facility produces several different compost blends and offers an information pamphlet for customers and maintains a website containing user information.
30. The facility has three temperature probes. The temperature probes are calibrated monthly. Temperature probe calibration records were observed. Thermometers were last calibrated on March 15, 2022. 31. Temperature readings are written on a temperature form at the windrow and information is loaded into an
excel spreadsheet developed by Brooks Contractors. 32. Mr. AJ Brooks currently maintains this spreadsheet and temperatures for windrows were observed from February 3, 2021 through April 1, 2022.
33. Windrow records including temperature and turning intervals are maintained. PFRP was met on all windrows except two windrows that did not pass and was recycled into another active windrow which later passed PFRP according to Mrs. Fulford. 34. Compost analysis records were observed for nutrients, concentration of metals, manmade inerts, fecal coliform, and salmonella for samples observed from September 15, 2021 through March 3, 2022. The compost samples were analyzed by Soil Control Lab, Watsonville, CA. Mrs. Fulford stated that a new lab might be used to conduct the sampling soon. Compost sample analysis appeared compliant with Solid Waste Section rules. 35. The facility has a clay-lined stormwater pond. Stormwater can be pumped-out for use on windrows/in the active compost process. 36. The facility has a new water truck for dust control and windrow irrigation. Water truck was observed during this inspection suctioning water from the pond. 37. There was no odor detected at the facility boundary and minimal odor was detected at the windrows during this inspection. 38. The stormwater pond freeboard appeared to be at ~ 2 feet during this inspection. 39. Continue to repair and maintain the three sediment basins and stormwater pond as necessary. 40. Exterior diversion berms and internal grading appear to have good positive flow to the pond.
41. The facility had been issued a Division of Water Resources Land Application (Irrigation) of Industrial By Product Compost Leachate and Stormwater Runoff permit, No. WQ0036333, issued: 11/17/14 - expiration: 09/30/18. A letter was issued by the Division of Water Resources on June 14, 2019 stating that the subject permit is no longer required. 42. The Goldston Fire Department can be contacted to address and emergency at the facility. 43. The facility is secured by a metal gate with lock (the Brooks’ residence is located at the entrance
drive to the facility). Facility personnel are on site during operating hours. 44. Access roads are of all-weather construction.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 4

45. The facility has proper signage. 46. Effective November 1, 2019 15A NCAC 13B .1406 (19) (a) states in part that this facility “shall have an operator, supervisor or manager trained in accordance with the requirements in G.S. 130A-309.25.” Training requirements must be achieved and maintained by the US Composting Council Certification Commission or equivalent and this training shall be required every five years. 47. Per 15A NCAC 13B .1406 (19) (d) The above requirement shall be met by this facility within three years of the readopted rule date of November 1, 2019. 48. 15A NCAC 13B .1406 (19) (b) & (c) states “Owners or operators shall provide annual training for facility staff, including a review of the operations plan and permit documents. Documentation of training required in Sub-items (a) and (b) of this Item shall be maintained at the facility and made available to the Division upon request.” 49. The PTO expiration date is January 22, 2020. 50. The PTO renewal application was received by the SWS on September 27, 2019 and is currently under review.
Please contact me if you have any questions or concerns regarding this inspection report.
Phone: [phone]
Chuck Kirchner Environmental Senior Specialist
Regional Representative
Sent on: April 7, 2022 X Email Hand delivery US Mail Certified No. [ _]
Copies: Deb Aja, Western District Supervisor - Solid Waste Section