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HomeMy WebLinkAbout92M_INSP_20230112FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 6 UNIT TYPE: Lined MSWLF LCID X YW Transfer Compost SLAS COUNTY: WAKE Closed MSWLF HHW White goods Incin T&P FIRM PERMIT NO.: 92M-LCID CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: January 12, 2023 FACILITY NAME AND ADDRESS: Wall Recycling, LLC LCID Landfill and Treatment and Processing Facility 3000 Gresham Lake Road Raleigh, NC 27615 GPS COORDINATES: Lat.: 35.88326 Long.: -78.58590 FACILITY CONTACT NAME AND PHONE NUMBER: Name: Dan Wall, Owner, Wall Recycling, LLC Phone: 919-650-8353 Email: dan@wallrecycling.com Name: Dustin Hill, COO, Wall Recycling, LLC Phone: 919-896-1829 Email: dustin@wallrecycling.com Name: Dan Jarboe, Facility Manager, Wall Recycling, LLC Phone: 919-906-2747 Email: djarboe@wallrecycling.com FACILITY CONTACT ADDRESS: 2310 Garner Road Raleigh, NC 27610 PARTICIPANTS: Tim Davis, NCDEQ, Solid Waste Section Drew Hammonds, NCDEQ, Solid Waste Section Dustin Hill, Wall Recycling, LLC STATUS OF PERMIT: PTO expires February 7, 2023. Permit Modification, updated Operations Plan, and existing conditions drawing submitted to SWS on August 15, 2022. PURPOSE OF SITE VISIT: Comprehensive Compliance Inspection STATUS OF PAST NOTED VIOLATIONS: None FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 6 OBSERVED VIOLATIONS: A. 15A NCAC 13B .0203 (d), “By receiving solid waste at a permitted facility, the permittee shall be considered by the Department to have accepted the conditions of the permit and shall comply with the conditions of the permit.” Permit to Operate, Attachment 3, #11 states, “Revisions to the design or operation of the facility or changes to the facility service area must be submitted to the Section for review and approval prior to the implementation of any changes.” Although Wall Recycling sought and received the approval of an Air Curtain Incinerator (ACI) from the Division of Air Quality in 2020, it failed to modify its Solid Waste permit to allow the ACI to be used at the Gresham Lake facility. The facility had operated the ACI on top of the landfill to reduce volume of debris onsite in the days preceding the November 25th fire and had been incorporating the ash back into its operations. While it is not clear that these actions led to the fire itself, the use of the ACI is a violation of the facility permit. The ACI was in operation at the time of this inspection and should be discontinued until approved by permitting. B. 15A NCAC 13B .0566 (10)(a), “Open burning of solid waste is prohibited, unless approval has been obtained from the Division, the local government, and the Division of Air Quality in accordance with 15A NCAC 02D .1900 prior to any burning activity.” The Section understands that facilities are not immune from accidental fires, however, nothing in reviewed weather data or information obtained from the facility points to any cause which is outside the control of the facility operator. Further, the operation of the ACI without approval of the Section constitutes the open burning of waste. The length of time the fire burned, in addition to the occurrence of previous fires at this facility, raises concerns as to whether the facility, in accordance with .0566 (10)(c), was adequately prepared to address such a fire. C. 15A NCAC 13B .0101 (28), “’Inert debris waste’ means inert debris that consists solely of asphalt, cured concrete, brick, concrete block, gravel, and rock. Inert debris waste shall not contain chemical adhesives or sealants, or lead-based paint.” During this inspection the inert debris stockpile on the northwest side of the facility contained commingled waste including metal, plastic, fiberglass insulation, sealed/polished gravestones, composite quartz countertop waste, and painted brick and concrete. Commingled waste, sealed, painted, or composite stone material, and painted brick and concrete do not meet the definition of inert debris as defined in 15A NCAC 13B .0101 (28). Ensure all prohibited commingled waste, sealed, painted, or composite stone material and painted brick and concrete is removed and disposed of at a permitted facility. ADDITIONAL COMMENTS This facility is an LCID Landfill and T&P facility permitted to receive land clearing waste; yard trash; untreated and unpainted wood; uncontaminated soil; inert debris such as unpainted rock, brick, concrete block; and asphalt 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 generated within Wake County and all in accordance with NCGS 130-294(m). The following compliance issues in bold require action to address. 1. The correct signage is at the entrance of the facility listing the facility name, permit number, contact information, and a list of materials accepted at the facility. 2. The facility accepts waste Monday through Friday from 8:00 am to 5:00 pm and Saturdays from 8:00 am to 12:00 pm. The facility is secured by fences with locking gates. 3. The facility permit and waste screening logs were available and reviewed with facility staff. Ensure waste screening logs are up to date and conducted on at least 1% of incoming loads as stated in the Operations Manual. Ensure up to date copies of all pertinent documents, including the current Operations Manual, are kept onsite and are accessible to all facility personnel. Facility contact information and NCDEQ representative information also need to be updated. 4. The following are facility certified personnel: a. Dustin Hill, Certified Manager of Landfill Operations, SWANA ID# 1853784, exp. 6/21/25 b. Eleazar Medellin, Certified Specialist of Landfill Operations, issued 5/29/2020 5. 15A NCAC 13B .0564 (6)(b), “Buffer requirements: A site shall maintain the following buffer requirements: 100 feet from the waste boundary to property lines, residential dwellings, commercial or public buildings, and potable wells.” During this inspection, it appeared that the western waste boundary and inert debris waste stockpile has overtaken the previous perimeter road and is within 100 feet of the western property line. The waste needs to be moved away from the property line so that the 100- foot buffer requirement has been met. Ensure that necessary buffers are met for approved operational areas and that durable, easily visible property line markers are in place. 6. Permit to Operate, Attachment 3, #8, “Durable, permanent markers that accurately delineate the waste disposal boundary and are easily visible must be installed and maintained.” During this inspection, no edge-of-waste (EOW) markers were visible. Within 30 days of this report, install markers delineating the waste boundary for the LCID landfill. 7. 15A NCAC 13B .0564 (7), “The site shall establish and maintain an access road around the waste boundary for access by emergency or fire fighting vehicles or equipment.” A partial access road was identified around the waste boundary but remained incomplete at the time of this inspection. Some sections of a previous perimeter access road had been overtaken by the waste boundary. Ensure a perimeter access road around the waste boundary is established and maintained. 8. Permit to Operate, Attachment 3, #9, “Excavation, grading and fill material side slopes must not exceed a ratio of three horizontal feet to one vertical feet (3:1).” Side slopes of the LCID landfill were steeper than 3:1 in many areas, especially the southwestern and eastern side slopes. The southwestern slope had developed a long fissure that may result in the collapsing and shedding of material. The southeastern corner and side slope contains material that appears to have been dumped at random with no defined slope. Within 30 days of this report and as dry weather permits, regrade the side slopes of the landfill to the acceptable ratio of three horizontal feet to one vertical foot (3:1). 9. Section 2.5.1, page 21 of the Operations Manual states, “The yard operator will be present when each vehicle is unloaded to ensure the material is acceptable. This inspection will take place prior to unloading, but at a minimum soon after unloading and prior to the vehicle leaving the premises.” During this inspection, multiple vehicles were observed dumping loads indiscriminately and without supervision, primarily in the T&P raw material area, resulting in commingled and unacceptable waste within the inert debris stockpile. Ensure facility staff are present in the T&P inert debris stockpile area to inspect incoming loads for unacceptable material. 10. Permit to Operate, Attachment 3, #24, “Solid waste must not be disposed in standing water. Surface water must be diverted away from the operational area and must not be impounded over or in waste.” During this inspection, several operational areas had water ponding in and around them and water FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 6 was impounding over the LCID landfill. Within 30 days of this report, regrade/repair these areas so that surface water is shed from the landfill and does not pond in the operational areas. 11. Solid waste must be restricted to the smallest area feasible, compacted densely as practical into cells by proper construction management. 12. Side slopes of the landfill are overgrown with woody vegetation. Please mow and remove woody vegetation to allow complete inspection of the site. 13. The operator has expanded the mulch dyeing and storage footprint and is constructing a concrete pad for mulch storage adjacent to and within 100 feet of the northern property line. This facility must operate in accordance with the permit and approved operations plan. Unapproved changes to the operational area and footprint of the facility will require approval. Please follow the permit and approved operations plan for this facility. Any changes to the design or operations of this facility should be submitted to Permitting for review and approval before going forward. 14. During this inspection, concrete truck operators were observed washing out/off their trucks onto the ground adjacent to the mulch storage area. Mr. Hill stated that the trucks were not approved to do this and that this would not continue to be an issue. 15. Corrective measures are necessary as a result of this inspection and must be completed within 30 days receipt of this report. 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 Sent on: January 23, 2023 X Email Hand delivery US Mail Certified No. [ _] Copies (email): Jason Watkins, Field Operations Branch Head – Solid Waste Section Drew Hammonds, Eastern District Supervisor – Solid Waste Section Ed Mussler, Section Chief – Solid Waste Section Sherri Stanley, Permitting Branch Head – Solid Waste Section Chris Hollinger, Compliance Officer – Solid Waste Section Taylor Hartsfield, Raleigh Regional Supervisor - DAQ Dustin Hill, COO – Wall Recycling, LLC Dan Jarboe, Facility Manager – Wall Recycling FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 6 Digital photographs taken by Tim Davis on 1/12/2023. View of ACI actively being operated on top of landfill. View of burned material still emitting smoke and heat. View of commingled waste within inert debris stockpile. View of concrete waste with paint/coating. View of sealed countertop waste with mesh backing. View of waste boundary within 100 ft of western property line. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 6 of 6 View of fissure in southwestern slope. View of southeastern corner with no defined slope. View #1 of water impounded over waste. View #2 of water impounded over waste. View of overgrown side slope in need of mowing.