77001YWN_INSP_20230106

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined MSWLF LCID YW X Transfer Compost SLAS COUNTY: RICHMOND
Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: YWN-77-001
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: January 6, 2023 Date of Last Inspection: July 12, 2022
FACILITY NAME AND ADDRESS:
Richmond County Yard Waste Notification 191 Walter Kelly Dr, Rockingham, NC 28379 GPS COORDINATES: Lat: 35.014656 ° Long: -79.806254 ° FACILITY CONTACT NAME AND PHONE NUMBER:
Jerry Austin, Jr., Solid Waste/Recycling Director 910-997-8338, [e-mail] Bryan K Leggett, Assistant Public Works Director 910-997-8338, [e-mail]
FACILITY CONTACT ADDRESS: Richmond County YWN P.O. Box 368 Rockingham, North Carolina 28379

PARTICIPANTS: Jerry Austin, Public Works Director Bryan Leggett, Assistant Public Works Director
David Powell, NC DEQ – SWS STATUS OF PERMIT: YWN Renewal submitted 5/19/2022 RENEWAL required by June 1st of each Year.
PURPOSE OF SITE VISIT:
Comprehensive Inspection – Follow Up STATUS OF PAST NOTED VIOLATIONS: NA
OBSERVED VIOLATIONS: NA

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 2 of 10
ADDITIONAL COMMENTS
1. The purpose of this inspection was to conduct a follow up on the yard waste area after a previous fire, reported at the YWN on 3/26/2022, and previous corrective actions before that fire, that date back to December 2021. These corrective actions were delayed due to the large fire in early 2022 at the YWN, which later spread throughout the
notification. Transfer Station LOS Permit has a yard waste section in that permit, however that area is mostly addressed through its yard waste notification YWN-77-001 inspection reports. Fire has been out for some time and the ash from YWN was taken through the Transfer Station to Uwharrie Environmental. Documentation was
provided to the Section on 9/23/2022 of the hauling. Currently the notification has much new yard waste and some pallet waste onsite. Older composted material that has been left for many years has built up and still needs removing or utilizing properly. It should all be removed down to actual soil and built back with soil into a proper pad or base for operating a notification. Also, waste still needs removing to meet buffers to swales/ditches of 25 ft in places and windrows need proper separation. Access around the notification is needed and between windrows for firefighting and fire control. Unapproved waste needs removal to appropriate disposal site. All waste, including new waste taken, needs windrowing and proper separation. 2. Section following up through email, before this inspection, revealed that there was some misunderstanding between the Richmond County Staff and the Section on what “older waste” was subject to needing removal and there was more work to be completed. Section staff Mr. Powell provided a copy of previous inspection report dated 12/21/2021, which stated, “Discussions onsite consisted of the removal of pallet wood waste, if not
accepting at a boiler. Any older YW or ground up or composted material is still considered waste and must be removed for appropriate use or disposal site. If boilers will not take ground up pallet wood, then an alternative
plan should be ready to execute. It can be composted, if clean wood only, and can then be utilized as compost. However, it cannot just remain in the notification or grinding area, that would be disposal. The notification is for treatment, staging and processing. DEACS, Department of Environmental Assistance and Customer
Service 1-877-623-6748, may could find a use for this waste type to be recycled. In the event waste cannot be removed, then the County should consider altering its services of accepting pallets until this problem is solved and the waste removed. Consult also your engineering firm/consultant for ideas and check with the
Sections Permit Engineer, Ming Chao, for approval on that plan before putting into action.” It was determined that a follow up inspection was needed to evaluate conditions onsite and reevaluate what’s left that still needs removal and other corrective actions that may be necessary.
During that site visit follow up, on 1/6/2023, Mr. Powell and Mr. Leggett walked and discussed site and discussed options. Later, Mr. Powell reviewed with Mr. Austin and Mr. Leggett his findings before leaving. Mr. Powell explained all the older decomposed, composted or broken-down yard waste is still considered waste and cannot be used for a “base” to operate the notification. A proper base is needed which consists of soil and proper sloping. All waste should be removed to establish a proper soil base that meets rule. This notification is limited to a 2-acre size, certain buffers, certain waste types, and the waste is to be removed and utilized in certain approved avenues. If the waste isn’t removed, then becomes disposal, and yard
waste notifications are not approved for waste disposal. Mr. Powell encouraged Richmond County to discuss corrective actions with a consultant or engineering firm familiar with NC Solid Waste rules on how to best approach addressing the clean up of their site. The Section needs a realistic time frame and Corrective Action Plan to address these issues in order to avoid shutting down of the notification temporarily. Mr. Powell also explained that the Solid Waste Section had not received any correspondence on the Air Curtain Incinerator permit since May 2022 and the County cannot wait and rely on the possibility of permitting a new site to address the
issues at the notification. What was submitted to Section Permitting was incomplete and the Section responded with additional requests quickly after the applications submittal. It was also requested to have a conference call between Richmond County and Section Staff, Drew Hammonds and David Powell, once the County could
research certain plans and avenues for addressing onsite issues. On January 11, 2023, Richmond County and Section staff Drew Hammonds and David Powell discussed onsite conditions, and corrective actions. Richmond County followed up with a letter outlining some corrective actions, plans to find contractors to do the work
needed, although more information is still needed by the Section. Richmond County needs to update the
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Section with final plans of what action will be taken and a realistic time frame of completion, and any operational changes onsite at the property. 3. Based on discussions and onsite inspections, some of the mulch onsite at the YWN will be used for erosion
control, vegetation establishment and additional cover dressing for the closed MSW and other areas around the County landfill site. Be sure not to use more than 3 inches in depth and mulch YW cannot be used for Beneficial Fill. Older and more broken down, or composted over time, YW can also be utilized in this manner as well. No yard waste/mulch should go to the Public unless it meets the 15A NCAC 13B .1406 rules.
Some mulched waste on the closed MSW.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 10
View is SE from access road. Notification is on left. This depicts the deeper side of older waste that needs removal.

Older waste has built up on the southern half of the notification the most it seems. Some mulched waste is in windrows of proper size and spacing on this end.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Along back side of notification along swale/ditch. View is ~ SW.
Northern corner of notification at access road. Closed MSW in background. Mulched waste has built up around entrance to notification and beginning of swale/ditch.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 6 of 10

View is NW. Waste inside of ditch/swale buffer and unapproved waste needing removal. Older waste is built up in this area as well needing removal.
Looking at large pile of newer, un-mulched waste. All waste should be windrowed with 25 ft separation for fire fighting and to limit spread of fire if catches.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Current clean pallet stockpile. May need to stop taking pallets in short term to address corrective actions. 4. In future, better placement and sizing of the windrow should be emphasized to minimalize one windrow from catching the others on fire. It is unknown if that would have helped in this fire but be sure and remember lessons learned during this event to try and prevent it from reoccurring in the future. Transfer Station Permit Attachment 3, Part (7), 21 - The permittee must store or stockpile the received waste or processed/ground material (such as mulch) in the following manner: a. Each windrow has the maximum height of 30 feet and the width of 50 feet at any time. b. Each windrow shall be maintained at least 25-foot clear distance or perimeter from drainage ditches and swales, around the processing area, and other stockpiles of raw wastes and ground material to allow
for inspection, monitoring temperature, or firefighting. c. Each windrow shall be maintained at least 50-foot clear distance from property boundaries.
5. Edge of Waste (EOW) markers are present and represent the limits that are being used currently. However, they need to be reinstalled in correct locations once work onsite is completed. Be sure the accurately mark the 2 acre or less notification as well as comply with buffers.
6. Upcoming ACI was discussed. Be sure and get all approvals, plans and maps and build according to what’s approved. A Pre-operational inspection will be needed before ACI can operate as well as certain conditions
satisfied. It may be sometime before this can start taking waste and take some of the pressure off the YWN. YWN will still be needed for the waste that cannot be allowed in the ACI. A new application was submitted to Section permitting on 1/6/2023 after discussing with Richmond County Staff and the Counties Engineering firm
Smith and gardener. Please submit any documentation associated with this site to myself and Ming Chao with Permitting. Please be sure and follow up with Ming Chao to be sure Permitting has everything they need to continue permitting process and respond to comments in timely manner.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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ACI area behind office being prepared currently.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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ACI area behind office being prepared currently. 7. Consult your engineering firm/consultant for ideas and check with the Sections Permit Engineer, Ming Chao, for approval before altering any process/plans at the permitted facilities. Ming Chaos’ contact number is (919) 707 – 8251 and [e-mail].
8. Update – before this inspection was completed, an update of onsite progress was submitted. Mr Leggett informed the Section of onsite progress or earth work to remove and replace with soil. They are still awaiting contractor bids for trucking and hauling waste. Photos were submitted in addition, good job. 9. Corrective measures are necessary as result of this inspection and should be met within 30 days receipt of this inspection. Failure to meet the conditions for compliance may result in Compliance Actions. A follow up inspection will be needed to confirm the corrective actions have been addressed. Given the nature of the situation and the corrective actions, it may take longer time. If additional time is needed, please
communicate with Mr. Powell and discuss before end of the deadline timeframe. Submit to the Section a realistic time frame of completion and a complete corrective action plan.

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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Please contact me if you have any questions or concerns regarding this inspection report.
________________________________________ Phone: [phone] _
David Powell Environmental Senior Specialist Regional Representative
Sent on: 1/19/2023 X Email Hand delivery US Mail Certified No. [ _]
Copies: Drew Hammonds, Eastern District Supervisor - Solid Waste Section Ming Chao, Environmental Engineer – Solid Waste Section