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HomeMy WebLinkAbout9223_INSP_20221108FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 5 UNIT TYPE: Lined MSWLF LCID X YW Transfer Compost SLAS COUNTY: WAKE Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 9223-LCID-2010 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: November 8, 2022 FACILITY NAME AND ADDRESS: Buffaloe LCID Landfill and Wood Processing Facility 5525 Wake Academy Dr Raleigh, NC 27603 GPS COORDINATES: Lat.: 35.70483 Long.: -78.66667 FACILITY CONTACT NAME AND PHONE NUMBER: Tommy Williams, Landfill Manager, 919-772-4166, wsgradingco@bellsouth.net FACILITY CONTACT ADDRESS: 5525 Wake Academy Dr Raleigh, NC 27603 PARTICIPANTS: Tim Davis, NCDEQ Andrew Hammonds, NCDEQ Tommy Williams, Buffaloe LCID Landfill William Williams, Buffaloe LCID Landfill STATUS OF PERMIT: Permit to Construct and Operate Buffaloe LCID Landfill Phases 2,3 4, and 5 issued 9/24/2019; expires 9/24/2024. Permit to Operate Buffaloe Wood Processing Facility issued 9/24/2019; expires 9/24/2024. PURPOSE OF SITE VISIT: Comprehensive Compliance Inspection STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS: A. 15A NCAC 13A .0566 (2), “Solid waste in the landfill shall be compacted. Slopes shall not exceed a ratio of three horizontal to one vertical at any time.” Permit Approval to Operate, Attachment 3, Part V (7), “Excavation, grading, and fill material side slopes must not exceed three horizontal to 1 vertical (3:1).” During this inspection, the northeastern slope of the landfill, which contains the inert debris working face, was identified as having a slope of one horizontal to one vertical. The base of the working face has been excavated below the natural ground level, resulting in a working face of approximately 60 feet in height. This area exceeds the required ratio of three horizontal to one vertical and poses a safety risk to facility personnel and landfill customers. Ensure the inert debris working face is regraded to achieve a slope of 3:1. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 5 ADDITIONAL COMMENTS The facility is an LCIDLF and T&P Wood Processing Facility and is permitted to receive for disposal land clearing waste; yard trash; untreated and unpainted wood; uncontaminated soil; inert debris such as unpainted rock, brick, concrete, and concrete block; and asphalt in accordance with the N.C.G.S 130A-294(m). 1. The facility is properly secured by a locking fence. Personnel are on site during operating hours. The facility is in operation 7:00am to 4:45pm Monday to Friday, and 8am to 11:45am Saturday. The facility has proper signage. 2. Facility permit and site plan were available and reviewed with facility staff. Ensure a copy of the facility operations plan with updated NCDEQ contact information is maintained on-site. 3. Roads are of all-weather construction and are in good condition. Asphalt accepted at the facility is used to maintain haul roads. 4. Permit Approval to Operate, Attachment 3, Part V (6), “Solid waste must be restricted to the smallest area feasible, compacted as densely as practical into cells by proper construction equipment.” During this inspection, multiple stockpiles of concrete waste were present throughout the landfill footprint. Concrete waste should be stockpiled in a single designated area, and at least 75% of the waste should be repurposed onsite, disposed of in the landfill, or hauled off-site within 1 year of receipt. Ensure waste is kept to the smallest possible space and covered every 30 days or as necessary to achieve a working face of no larger than 1 acre in size. 5. Quartzite and polished stone countertop waste with adhesive backing was observed within a concrete stockpile adjacent to working face. These materials are prohibited in an LCIDLF. Ensure all countertop material waste is removed and disposed of properly, and that future incoming loads containing such waste are rejected and hauled to a facility permitted to accept such waste. 6. Permit Approval to Operate, Attachment 3, Part V (11), “The permittee shall conduct monitoring of explosive gases semi-annually at the property boundaries and within any facility structures and maintain the monitoring log in the operating record according to the approved plan in Document No. 5 (FID 1256322). The concentration of explosive gases generated by the LCIDLF facility must not exceed: a. Twenty-five percent (25%) of the lower explosive limit for the gases in facility structures. b. The lower explosive limit for the gases at the property boundary.” The approved “Operations Plan” for this facility dated July 19, 2019 states, “Adjacent properties to the east and west will be monitored with a series of permanent gas monitoring wells as shown on the attached drawings. Explosive gas monitoring will be conducted at least semi-annually. All permanent gas monitoring wells will be sampled as well as onsite buildings.” Ensure explosive gas monitoring is conducted semi-annually as required in the permit and approved operations plan. Please contact Sherry Stanley, Permitting Branch Head to ensure the plan is still viable for this facility. 7. During this inspection, it was noted that a mulch layer several feet thick had been applied to an earthen ridge along the western property line adjacent to the access road. Mr. Williams stated that the equipment used for applying and spreading mulch was not currently operational. Mulch used for stabilization purposes outside the waste disposal boundary should be no more than 6 inches in depth. Ensure mulch 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 5 located on the western ridge, as well as other areas, is spread to achieve and maintain a 6-inch maximum depth. 8. Small woody vegetation was observed growing on the western side slope. Ensure any trees or woody vegetation is removed or rough cut to maintain the vegetative cover of the landfill and prevent damage to the landfill cap. Vegetation with a trunk or stem larger than 6 inches in diameter should be removed. 9. Permanent edge of waste (EOW) markers that accurately delineate the waste disposal boundary must be maintained. EOW markers should be placed at a frequency in which they are visible from one to the next. 10. Grinding is permitted on top of the LCID landfill, and ground wood is predominantly sold as boiler fuel. Incoming land clearing debris is being processed for grinding by removing the soil and attached root mat. Large amounts of root mat were observed in the soil being stockpiled for use as operational cover. Ensure wood waste, including root mat, is removed from soil intended for use as operational cover. 11. Mr. Williams stated that the facility wood grinding activities were producing more material than the facility could use or sell. Mr. Hammonds recommended composting as way to deal with excessive ground wood waste. He also recommended Mr. Williams contact permitted composting facilities in the area which would accept such waste to reduce the stockpile. The Division of Environmental Assistance and Customer Service (DEACS) is a resource which could help with this endeavor and can be reached at 1-877-623-6748. 12. The facility operator is interested in an air curtain incinerator for burning excess woody vegetation. Please contact Division of Air Quality (DAQ) staff for further information concerning this permit. Section staff can meet with the DAQ staff and operator if necessary to have further discussions. 13. Water within the working face excavation pit is pumped to a ditch and flows to the sediment basin located on the southside of the landfill. Excess sediment was observed within the basin. Erosion and sedimentation measures should be cleaned out as often as necessary to maintain proper functionality. 14. Old landfill may need to be closed and certified in accordance with the closure rules for LCID Landfills. Section staff will follow up on this. Mulch more than one foot in depth was observed spread out over a portion of the closed area. Mulch cannot be spread out in this manner for waste reduction. Excess mulch that cannot be sold or used properly must be disposed of. 15. Permit Approval to Operate, Attachment 3, Part V (3) & Part VII (24), “The estimated maximum disposal rate of the LCID landfill is 15,000 tons per year. The estimated maximum processing rate is 2,200 tons per year.” Mr. Williams stated that the facility took in approximately 31,000 tons of waste in 2021-2022, which includes wood waste and processed material. 31,000 tons exceeds permit limitations. Revisions to the design or operation of the facility should be submitted to permitting for review and approval prior to moving forward. 16. Digital photographs were taken during this inspection. Please contact me if you have any questions or concerns regarding this inspection report. ________________________________________ Phone: 919-707-8290 Tim Davis timothy.davis@ncdenr.gov Environmental Senior Specialist Regional Representative FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 5 Sent on: December 2, 2022 X Email Hand delivery US Mail Certified No. [ _] Copies (email): Drew Hammonds, Eastern District Supervisor – Solid Waste Section Ken Jensen, Office Manager – Buffaloe LCID Landfill Digital photographs taken by Tim Davis on 11/8/2022. View #1 of northeastern slope and working face. View #2 of northeastern slope and working face. View of prohibited countertop material within concrete stockpile. View of mulch layer on ridge along western property line. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 5 View of mulch layer exceeding 6” on old landfill. View of sediment basin on southside of landfill.